LeadingAge NY Submits Comments on Medicare SNF Payment Rule
Late last week, LeadingAge New York submitted written comments to the Centers for Medicare & Medicaid Services on the proposed rule for the federal fiscal year (FY) 2016 Medicare Skilled Nursing Facility (SNF) Prospective Payment System (PPS). The LeadingAge NY Nursing Facility Cabinet discussed the proposal in detail and provided extensive feedback reflected in our comments. CMS has posted a summary of the 43-page proposed rule entitled: Proposed Fiscal Year 2016 Payment and Policy Changes for Medicare Skilled Nursing Facilities.
The proposed rule would set the stage for shifting Medicare payments to SNFs from volume to value. CMS has set measurable goals and a timeline to move Medicare toward paying providers based on the quality, rather than the quantity of care they give patients. To this end, the proposed regulation would establish a SNF Value-Based Purchasing (VBP) Program beginning in FY 2019 under which SNFs would receive incentive payments based on performance on a SNF 30-Day All-Cause hospital Readmission Measure. Our comments expressed concern with basing the SNF VBP program solely on hospital readmissions, and called for consistency and transparency among hospital readmission measures used across Medicare and Medicaid.
The rule would also establish a SNF Quality Reporting Program (QRP) using measures addressing three quality domains: (1) skin integrity and changes in skin integrity; (2) incidence of major falls; and (3) functional status, cognitive function, and changes in function and cognitive function. Beginning in FY 2018, SNFs that fail to submit required quality data to CMS under the QRP will have their annual Medicare PPS updates reduced by two percent. LeadingAge NY provided CMS with technical and policy comments on the proposed measures.
Finally, the proposed rule would require long-term care facilities to electronically submit quarterly payroll data to include the category of work performed and hours of work provided by each category per resident per day – distinguishing facility employees from agency and contract staff – and that is verifiable and auditable, beginning July 1, 2016. Required information would include submission of each individual's start date, end date (if applicable) and hours worked for the purpose of calculating turnover and retention. Our comment letter raised several questions and concerns related to the costs and mechanics of gathering and reporting the staffing data.
Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866