FY 25 SNF Prospective Payment System Proposed Rule

FY 25 Skilled Nursing Facility Prospective Payment System Proposed Rule (CMS 1802-P)

For FY 2025, CMS proposes updating SNF PPS rates by 4.1% based on the proposed SNF market basket of 2.8%, plus a 1.7% market basket forecast error adjustment, and a negative 0.4% productivity adjustment. … CMS is proposing to expand its ability to impose financial penalties to drive sustained correction of health and safety deficiencies. These revisions will allow CMS to expand the mix and number of penalties in response to situations that put residents’ health and safety at risk and, therefore, encourage facilities to promptly correct and maintain lasting compliance with CMS’s health and safety requirements. … [CMS also] propose[s] an update of the Review and Correction policy that [it] previously finalized for the Program, to ensure that SNFs can review and correct Payroll-Based Journal (PBJ) data beginning with the FY 2026 program year and MDS data beginning with the FY 2027 program year.

Centers for Medicare & Medicaid Services. “FY 25 Skilled Nursing Facility Prospective Payment System Proposed Rule (CMS 1802-P).” Centers for Medicare & Medicaid Services, 28 March 2024. https://www.cms.gov/newsroom/fact-sheets/fy-25-skilled-nursing-facility-prospective-payment-system-proposed-rule-cms-1802-p

CMS Officials Offer Glimpse Into Proposed Changes To Value-Based Purchasing for Nursing Homes

The turnover measure only includes individuals who worked at least 120 hours and the 90-day period starts from the first workday observed across the baseline quarter… both regular employees and agency staff are included in the turnover measure if they worked sufficient hours to be eligible. … The nursing staff turnover measure is calculated using data from payroll-based journal (PBJ).

— Skilled Nursing News, May 7, 2024

‘Aggressive’ CMS Penalties for Nursing Homes in New SNF Rule Could Be Subject To Political Swings

“Whether you’re a five-star facility or a one-star facility, we are all at risk of receiving an immediate jeopardy citation with just one incident,” she said. “This could result in a per-day CMP, but under this new rule, it would mean per day and per instance, potentially leading to much higher expenses for a single incident resulting in an immediate jeopardy citation.”

— Skilled Nursing News, April 12, 2024

Experts fear ‘bigger, stronger stick’ in new Medicare pay rule

“It is disappointing that the CMS is not only choosing, again, to use the stick rather than the carrot, but is choosing a bigger, stronger stick,” said Jodi Eyigor, Director of Nursing Home Quality Public Policy for national provider association LeadingAge. “While we agree that deficient practice must be corrected for the safety and wellbeing of residents, CMS continually chooses to take responsibility only to the point of punishment while still prohibiting surveyors from offering any guidance to correct deficient practice when they see it.”

— McKnight’s Long-Term Care News, April 1, 2024

[UPDATED] BREAKING: CMS proposes 4.1 percent nursing homes pay boost; staffing minimum not addressed

The agency has proposed an update of the Review and Correction policy that it previously finalized, to ensure that SNFs can review and correct Payroll-Based Journal (PBJ) data beginning Oct. 1, 2025, and MDS data beginning Oct. 1, 2026. … “While we appreciate this proposed increase, this funding will not stem the tide for the billions of dollars that will be required by providers each year to meet the agency’s proposed staffing minimum requirement,” said American Health Care Association President and CEO Mark Parkinson.

— McKnight’s Long-Term Care News, March 29, 2024

Skilled nursing facility proposed rule updates payment rates, VBP program

CMS proposed administrative policy updates, including modifying the Review and Correction policy to ensure SNFs can review and correct Payroll-Based Journal (PBJ) data starting with the FY 2026 program year and MDS data starting with the FY 2027 program year. … CMS proposed expanding the existing nursing home enforcement authority to allow the agency to impose financial penalties for health and safety risks. … The proposals would allow CMS to impose per instance and per day penalties concurrently, following statutory daily limits.

— RevCycleManagement / TechTarget, March 29, 2024

MedPAC member: Give Congress more on nursing home staffing mandate implications

“This rule would massively change the industry,” [Dr. Brian Miller] added. “I am generally supportive of the current recommendation, but again, I wonder if we lack the specificity, given that we expect this enormous change in how SNFs do business.” … “I feel like we’d be a better advisor to the Hill and Congress if we had some sort of estimate of what the impact would be on SNF margins.”

— McKnight’s Long-Term Care News, January 12, 2024

As a ‘Better Advisor’ to Congress, MedPAC Mulls CMS Staffing Mandate Effects But Proposes 3% Medicare Cut

The majority of MedPAC board members voted Thursday to recommend reducing Medicare-based payment rates for skilled nursing spending by 3% for 2025, despite voicing concerns about the federal minimum staffing proposed rule. … “[The proposed staffing mandate] would massively change the industry,” said MedPAC board member Dr. Brian Miller. “Knowing that there’s that proposed rule, which would significantly affect the SNF margin because it would totally change their operations, should we have two estimated recommendations, one based upon the current statute and regulatory framework and another based upon if this rule were implemented next year?”

— Skilled Nursing News, January 11, 2024