With our industry’s focus on the COVID-19 public health emergency, this year’s Final Rule addresses essential policies only, while incorporating some impactful PDPM updates. There is a strong theme emphasizing a continued commitment to keeping providers connected through electronic means to promote the exchange and reuse of patient assessment data. The MDS is at the top of that list with discharge information being critical to ensure necessary medical information is shared and transferred among post hospital settings. The MDS will not have the anticipated major over haul until 2 years from the end of the Public Health Emergency, likely October 2022. This is good news for interdisciplinary teams that have been adjusting to many related changes and communication methods. Accuracy and collaboration remain critical for the current environment as well as future changes.
What’s in the Final Rule for FY21?
In accordance with the legal requirement to update payment policies every year, Centers for Medicare and Medicaid Services (CMS) issued the 2021 Final Rule for SNFs late Friday afternoon (July 31) found here (CMS-1737-F).
Perhaps the most noteworthy update is the 2.2% (~$750 M) increase in prospective payment rates for FY 2021, which is slightly less than what was outlined in the Proposed Rule in April but will help to off-set the distressing PPE and staffing costs.
Specifically, there are no updates related to SNF QRP, and only minor updates to the SNF VBP that do not affect payment terms, quality measures or scoring. For more highlights, review CMS’ fact sheet found here and note the few changes related to:
- ICD-10 code mappings used under SNF PPS for classifying patients into case-mix groups under PDPM. Download the most up to date Mapping Documents from the CMS PDPM landing page.
- OMB delineations used to identify a facility’s status as urban or rural for wage index calculations. (There will be a 5% cap on wage index decreases between fiscal 2020 and 2021.)
- The 30-day Phase One Review and Correction deadline will be applied to the baseline quality measure quarterly report (typically issued in December) and allow 30 days for SNFs to issue corrections.
The SNF industry may be taking a collective sigh of relief in response to Friday’s Final Rule announcement. HealthPRO Heritage advises now is the opportune time to shore up fiscal sustainability inclusive of the following strategies:
- Understand the extent to which the Medicare waivers (in effect thru at least October) can benefit your clinical and fiscal outcomes, and use Q3 to optimize PDPM reimbursement smarts NOW (especially for providers in regions where COVID-19 outbreaks have been minimized). Enlist the support of consultative experts as needed and seek out education/training on fiscal success drivers.
- Fortify an iron-clad approach to infection prevention. To that end, learn more about the new role of the Infection Preventionist.
- Refine partnerships with upstream and downstream providers starting with careful data/outcomes analysis + well-defined goals for clinical capabilities and care delivery. After all, census & network development will be key to sustainability.
- Optimize all service lines (especially Therapy Services) to guarantee collaboration among IDT, to improve clinical outcomes, and to assure fiscal sustainability for the long-term. Contact HealthPRO Heritage to explore competitively priced options.