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Nothing to See Here: Proposed Rule FY2021 Outlines (Thankfully) Unremarkable Changes

On Friday (April 10), CMS issued the FY2021 SNF PPS Proposed Rule (effective October 1, 2020) and proposes unsurprising payment rate adjustments, changes to the case-mix classification code mappings, and tweaks for the SNF Value-Based Purchasing (VBP) Program. Considering recent pressures related to the COVID-19 crisis, the SNF industry is taking a collective sigh of relief.

Some proposed changes worthy of highlighting are outlined below, and/or access the actual Proposed Rule here. Reminder: The comment period is open until June 9.

SNF Proposed Payment Updates
An approximate increase of $784 million in payments to SNFs is proposed for FY 2021. This does NOT include SNF VBP reductions estimated at $199.54 million in FY 2021. CMS will redistribute about $329.09 million in value-based incentive payments to SNFs in FY 2021.

The combined effects of all changes vary by specific types of providers and by location. For example, rural providers will get a 2.5% increase versus a 2.3% increase across the 15,000 providers nationwide, and urban New England-based providers will get 1.0% while urban pacific region-based providers will get a 2.5% increase. Small rural hospitals (outside MSA with <100 beds) with swing beds or SNF based units will get a 2.3% increase.

Proposed New CBSAs
To take into account local economies and regional wage indices, new CBSAs are proposed: 34 urban counties that would become rural and 47 rural counties that would become urban. CMS proposes allowing for a 1 year transition (from October 1, 2020 thru September 30, 2021) for markets that would see a decrease to apply a cap of only 5% to the wage index, and allows for SNFs that would experience an increase in wage index values will receive the full benefit of their increased wage index value. Some counties will be selected to split apart (resulting in either a negative or positive consequence) while other select counties may see only a change in name/number. 

ICD-10 Mapping Changes
CMS is proposing changes that opens up opportunity for mapping to better classifications to the ICD-10 code mappings and lists (specifically, two surgical clinical category options: “May be Eligible for the Non-Orthopedic Surgery Category” or “May be Eligible for One of the Two Orthopedic Surgery Categories.”) Visit the CMS website here for proposed updated mappings and lists.

SNF VBP Key Take-Aways

  • The Proposed Rule indicates: The term "SNF Readmission Measure” will be changed to "Skilled Nursing Facility Potentially Preventable Readmissions after Hospital Discharge Measure."
  • CMS reported a standard readmission rate: 19.67 and mean incentive multiplier: 0.99251
  • No changes to the data Suppression Policy for low-volume SNFs. Instead, CMS plans to codify the data though within the SNF VBP regulations.
  • The SNF VBP performance data will be publicly reported on Nursing Home Compare or a successor website and will include: range of SNF performance scores; the number of SNFs receiving value-based incentive payments; and the range and total amount of those payments. NOTE: SNFs with <25 qualifying stays, low/zero volume will not have data displayed.
  • To simplify/streamline navigation: CMS plans to combine/standardize eight existing Nursing Home Compare tools so users can access information currently divided between Nursing Home Compare and Hospital Compare through a single point of entry.
  • Remember: Sequestration has been put on hold for May 1, 2020 to December 31, 2020, but your rate will still be affected by VBP.

30-Day Phase One Review and Correction Deadline
CMS proposes to apply the 30-day Phase One Review and Correction deadline to the baseline period quality measure quarterly report (typically issued in December) and allow 30 days for SNFs to submit a correction request for inaccurate data. Beginning with the baseline period, quality measure quarterly report issued on or after October 1, 2020 that contains the baseline period measure rate and all of the underlying claim information used to calculate the measure rate that applies for the fiscal year, SNFs will have 30 days following the date that CMS provides these reports to review and submit corrections for the data contained in these reports. Any such correction requests must be accompanied by appropriate evidence showing the basis for the correction.

Comments Related to PDPM
In the Proposed Rule, CMS states that it continues “to monitor the impact of PDPM implementation on patient outcomes and program outlays, though we believe it would be premature to release any information related to these issues based on the amount of data currently available.” CMS notes that it continues to monitor the impact of PDPM, stating that it may reconsider the adjustments made in the FY 2020 SNF PPS final rule to the case-mix weights used under PDPM to ensure budget neutrality and recalibrate these adjustments as appropriate.

Tags: CMS Update 2020