OK, hear us out.
Medicare payment policy was updated staving off the proposed parity adjustment, adding $410 Million in Medicare Part A payments. The Value-Based Purchasing program data will be suppressed and the Quality Reporting Program had confirmed updates to include measures for infection control and COVID-19 vaccination reporting. Both programs are geared towards advancement and holding nursing facilities to a higher standard of value-based quality care.
Most providers have reviewed the FY 2022 SNF PPS Final Rule that was released July 29th with the overall reaction being: “It could have been worse…” But HealthPRO Heritage experts urge SNFs’ leadership teams to interpret this (and all!) Final Rule revisions through a ‘Big Picture’ lens: Envision everything!
Add up all of the CMS’ Final Rule revisions over the past few years (e.g.: parity adjustments, QRP changes, therapy Part B cuts, PayGo, VBP initiatives, denials, survey & penalties, etc.) even the minor updates are important ‘clues’ to understand & predict CMS’ vision for the future of long-term care.
For example, while many are relieved that this week’s Final Rule pushed off the 5% parity adjustment for one year and the VBP policy will allow for many SNFs to receive 1.2% payback, HealthPRO Heritage warns SNF operators to consider important implications.
It is clear from the language and intent of this week’s Final Rule that CMS is determined to achieve RUG-IV-to-PDPM budget neutrality. But even with annual claw-back payments over ~5 or less years, we must anticipate CMS’ response to the very real possibility that PDPM may never be budget neutral as providers continue to optimize coding practices.
With budget neutrality an unlikely outcome, HealthPRO Heritage experts anticipate that CMS may move quickly towards value-based care with a unified post-acute payment system.
In short, SNF operators must anticipate and prepare for more major changes in reimbursement where all payers (not only Medicare) will expect more & pay less. The industry will absolutely need to (again) adapt by making the most of what’s available.
The best strategy for SNF operators is to lock down a progressive and efficient clinical model of care that will assure only the highest, reimbursable quality outcomes. Just as we tackle the challenges of providing care for patients under Medicare Advantage plans, providers will also need to maximize value-based incentives and seize opportunities to participate in episodic payment pilots. Never has this been more important than now for competing SNFs who need to be ‘the best’ at treating high acuity patients.
This practical strategy will require careful high-level planning + boots-on-the-ground implementation. As such, many SNF providers may choose to partner with clinical experts with proven success -- such as HealthPRO Heritage -- for support, resources, and execution. In fact, let’s do it together!
HealthPRO Heritage remains committed to supporting our partners and industry peers amidst these challenging headwinds. We Envision Everything: A way forward by anticipating, planning & executing on a clinically-driven model of care that’s optimally aligned with CMS’ ultimate vision for value-based reimbursement.
As always, it’s important to stay informed. That’s why SNF leaders can count on HealthPRO Heritage to offer resources & guidance, such as a summary of highlights RE: FY2022 SNF PPS, QRP, VBP Final Rule and a link to CMS’ Final Rule Fact Sheet here.
