/ en Fri, 15 Aug 2025 22:53:54 -0500 Fri, 01 Aug 25 13:36:12 -0500 /advisory/2025-08-01-cms-releases-fy-2026-skilled-nursing-facility-pps-final-rule <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) July 31 issued its fiscal year (FY) 2026 <a href="https://www.federalregister.gov/public-inspection/2025-14679/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities">final rule</a> for the skilled nursing facility (SNF) prospective payment system (PPS).</p><div><h2 id="keyhighlights">Key Highlights</h2><p>The final rule will:</p><ul><li>Increase aggregate SNF payments by an estimated 3.2% ($1.16 billion) in FY 2026 relative to FY 2025.</li><li>Make technical changes to its Patient-driven Payment Model (PDPM) ICD-10 code mapping that assigns patients to clinical categories.</li><li>For the SNF quality reporting program (QRP), remove four patient assessment data elements related to social drivers of health.</li><li>For the SNF value-based purchasing program (VBP), remove the program’s health equity adjustment.</li></ul></div><h2>AHA TAKE</h2><p>The AHA appreciates the higher-than-proposed final payment update. However, the AHA continues to be concerned about inadequate market basket updates and lagging forecast error adjustments for providers.</p><p>Highlights from the rule follow.</p><h2>FINAL SNF PPS PAYMENT CHANGES</h2><p>The rule will increase net payments to SNFs by 3.2% ($1.16 billion) in FY 2026 relative to FY 2025. This includes a 3.3% market-basket update offset by a statutorily mandated productivity cut of 0.7%, and increased by a 0.6% market-basket forecast error adjustment related to FY 2024.</p><p>CMS also finalized technical changes to its PDPM ICD-10 code mapping that assigns patients to clinical categories for payment purposes. In total, CMS is making 34 changes to the coding classification. These changes can be found on <a href="https://www.cms.gov/medicare/payment/prospective-payment-systems/skilled-nursing-facility-snf/list-federal-regulations/cms-1827-f">CMS’ site</a> for this rulemaking. </p><h2>SNF QUALITY REPORTING PROGRAM AND VALUE-BASED PURCHASING PROGRAM</h2><p><u>SNF QRP.</u> Beginning with the reporting period starting Oct. 1, 2025, CMS makes optional the reporting of four standardized patient assessment data elements in the Minimum Data Set focused on social drivers of health. This includes one item focused on living situation, two items focused on food insecurity and one item focused on utilities.</p><p><u>SNF VBP Program.</u> CMS removes the program’s health equity adjustment that otherwise would have gone into effect beginning FY 2027. The health equity adjustment would have awarded bonus points to SNFs based on a combination of their quality performance and the proportion of patients dually eligible for Medicare and Medicaid.</p><h2>NEXT STEPS</h2><p>Please contact Jonathan Gold, AHA’s senior associate director of payment policy, at <a href="mailto:jgold@aha.org">jgold@aha.org</a>, with any questions related to payment, and Caitlin Gillooley, AHA’s director of quality policy, at <a href="mailto:cgillooley@aha.org">cgillooley@aha.org</a>, regarding any quality-related questions.</p></div><div class="col-md-4"><a href="/system/files/media/file/2025/08/cms-releases-fy-2026-skilled-nursing-facility-pps-final-rule-advisory-8-1-2025.pdf" target="_blank" title="Click here to download the Regulatory Advisory: CMS Releases FY 2026 Skilled Nursing Facility PPS Final Rule PDF."><img src="/sites/default/files/2025-08/cover-cms-releases-fy-2026-skilled-nursing-facility-pps-final-rule-advisory-8-1-2025.png" data-entity-uuid data-entity-type="file" alt="CMS Releases FY 2026 Skilled Nursing Facility PPS Final Rule Cover." width="640" height="834"></a></div></div></div> Fri, 01 Aug 2025 13:36:12 -0500 Skilled Nursing Facility PPS /news/headline/2025-07-31-cms-finalizes-32-payment-update-snfs <p>The Centers for Medicare & Medicaid Services today issued a final rule for the <a href="https://www.federalregister.gov/public-inspection/2025-14679/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities" title="final rule">skilled nursing facility</a> prospective payment system for fiscal year 2026. The rule will increase aggregate payments by 3.2%, which reflects a 3.3% market basket update, a 0.7 percentage point cut for productivity, and an increase of 0.6 percentage points for the market basket forecast error for FY 2024.</p><p>For the SNF Quality Reporting Program, CMS will remove four patient assessment data elements related to social drivers of health. The agency also finalized its proposal to remove the previously adopted health equity score adjustment in the SNF value-based purchasing program.</p><p>The <a href="https://www.cms.gov/newsroom/fact-sheets/fy-2026-skilled-nursing-facility-snf-prospective-payment-system-final-rule-cms-1827-f" title="updates">payment updates</a> are effective Oct. 1, 2025. AHA members will receive a Regulatory Advisory with additional information. </p> Thu, 31 Jul 2025 16:39:54 -0500 Skilled Nursing Facility PPS /lettercomment/2025-06-10-aha-comments-cms-skilled-nursing-facility-fy-2026-proposed-payment <p>June 10, 2025</p><p>The Honorable Mehmet Oz, M.D.<br>Administrator<br>Centers for Medicare & Medicaid Services<br>7500 Security Boulevard<br>Baltimore, MD 21244-1850</p><p><em><strong>Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program for Federal Fiscal Year 2026; 90 Fed. Reg. 18,950 (April 30, 2025).</strong></em></p><p>Dear Administrator Oz:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 500 skilled-nursing facilities (SNFs), our clinician partners — more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2026 SNF prospective payment system (PPS) proposed rule.</p><p>SNFs play a critical role in the continuum of care; ensuring access to this frequently-utilized discharge destination is critical for patients continuing their recovery following a hospitalization. However, as the AHA highlighted in our comments on <a href="/lettercomment/2023-06-05-aha-comments-fy-2024-proposed-rule-skilled-nursing-facilities">prior rulemakings,</a> hospitals have faced increasing difficulty discharging patients to post-acute care, including SNFs. Staffing shortages and inadequate payment updates have contributed to the barriers to SNF care, as has the rapid expansion of beneficiary enrollment in Medicare Advantage (MA). The latter increases SNFs’ costs while reducing patient access and coverage, particularly through the inappropriate use of prior authorization. These shortfalls then place additional burden back on hospitals, which face extended lengths of stay for patients in need of post-acute care. <strong>While we appreciate that addressing concerns related to MA plans is outside of the scope of these comments, we encourage CMS to ensure that Traditional Medicare policies facilitate access to SNF services, rather than create barriers to care. Specifically, we urge CMS to provide adequate, timely payment updates for SNFs, including by re-examining the magnitude of its market basket updates and productivity adjustments.</strong></p><p>Additionally, AHA appreciates CMS’ efforts to alleviate reporting burden on providers. <strong>Specifically, the AHA supports CMS’ proposal to remove four standardized patient assessment data elements (SPADEs) from the SNF QRP and greatly appreciates CMS’ recognition of the need to balance administrative burden and value in quality measurement programs</strong>. By streamlining reporting requirements, CMS can free providers to focus on the quality and safety issues that matter the most to their patients. In addition, the AHA provides in this comment letter an overview of its response to CMS’ Request for Information (RFI) on approaches and opportunities to streamline regulations and reduce administrative burdens on providers.</p><p>Our detailed comments follow.</p> Tue, 10 Jun 2025 15:25:18 -0500 Skilled Nursing Facility PPS /news/headline/2025-06-10-cms-urged-provide-more-appropriate-timely-payment-updates-snfs-fy-2026 <p>The AHA June 10 <a href="/system/files/media/file/2025/06/aha-comments-on-cms-skilled-nursing-facility-fy-2026-proposed-payment-rule-letter-6-10-2025.pdf" target="_blank">urged</a> the Centers for Medicare & Medicaid Services to provide more adequate and timely payment updates for skilled nursing facilities in comments to the agency on the fiscal year 2026 SNF <a href="/news/headline/2025-04-11-cms-proposes-28-payment-update-snfs" target="_blank">prospective payment system proposed rule</a>. The AHA said it remains concerned about inaccurate market basket updates and that forecasts used by CMS in recent years underestimated market basket growth. For FY 2026, SNFs are proposed to receive a 3.0% market basket update, a 0.8 percentage point cut for productivity and an increase of 0.6 percentage points for a market basket forecast error for FY 2024.</p> Tue, 10 Jun 2025 15:23:10 -0500 Skilled Nursing Facility PPS /2025-05-15-skilled-nursing-facility-pps-proposed-rule-fy-2026 <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) April 11 issued its fiscal year (FY) 2026 <a href="https://www.federalregister.gov/documents/2025/04/30/2025-06348/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities" target="_blank" title="April 11 proposed rule">proposed rule</a> for the skilled nursing facility (SNF) prospective payment system (PPS). This rule proposes to update SNF payments and modify the SNF quality reporting program (QRP) measures and reporting requirements.</p><div class="panel module-typeC"><div class="panel-heading"><p><strong>KEY HIGHLIGHTS</strong></p><p>The proposed rule would:</p><ul><li>Increase aggregate SNF payments by an estimated 2.8% ($997 million) in<br>FY 2026 relative to FY 2025. This includes a 3.0% market basket update<br>reduced by a 0.8% productivity cut and a 0.6% increase due to a FY 2024<br>market basket forecast error.</li><li>For the SNF QRP, remove four patient assessment data elements.</li><li>For the SNF value-based purchasing program (VBP), remove the program’s health equity adjustment.</li><li>Solicit comments on approaches and opportunities to streamline regulations and reduce administrative burdens on hospitals and other providers.</li></ul></div></div><h2>AHA TAKE</h2><p>This proposed rule does not make any major or unexpected payment changes to the SNF PPS. AHA remains concerned about lagging market basket updates in the face of increasing financial pressures and staffing requirements on SNFs. Nonetheless, we appreciate CMS’ interest in regulatory relief and will be pursuing opportunities to lessen burdens on providers.</p><h2>WHAT YOU CAN DO</h2><ul><li><strong>Share this advisory </strong>with your senior management team to examine the impact these payment changes would have on your organization in FY 2026.</li><li><strong>Attend an</strong> <a href="https://aha-org.zoom.us/webinar/register/WN_QVOCu7XTTFygFK9Ey9aZAw#/registration" target="_blank" title="AHA May 20th webinar">upcoming AHA webinar on May 20</a> on the proposed rule.</li><li><strong>Submit to CMS by June 10 a comment letter</strong> explaining the rule’s impact on your patients, staff, facility and local health care partners. Comments may be submitted at <a href="http://www.regulations.gov/" target="_blank">www.regulations.gov</a>. The final rule will be effective Oct. 1, 2025.</li></ul><h2>PROPOSED FY 2026 SNF PPS PAYMENT AND COVERAGE UPDATES</h2><p>CMS estimates that this proposed rule would increase SNF PPS payments by 2.8%, or $997 million in FY 2026 relative to FY 2025. This update is the result of a market basket update, a productivity adjustment and a market basket forecast error adjustment. CMS also proposes updated standardized payment rates, updated case-mix weights, adjustments to the labor-related share of payment and new categories for primary ICD-10 diagnosis codes. In addition, CMS is requesting feedback on items and services to be excluded from consolidated billing requirements.</p><p><strong>Proposed FY 2026 Payment Updates. </strong>The proposed rule would increase net payments to SNFs by an estimated 2.8% or $997 million in FY 2026. This includes a 3.0% market-basket update offset by a statutorily-mandated productivity cut of 0.8%. It also includes a positive 0.6% market basket forecast error adjustment for FY 2024, in which the actual market basket change has been shown to be higher than what was implemented in that year.</p><p>After applying these updates, as well as a budget neutrality factor for proposed changes to the wage indexes (discussed below), CMS provides the following unadjusted per-diem rates for the various components of the Patient-Driven Payment Model (PDPM), found in Tables 3 and 4 of the proposed rule. These proposed increases are approximately 2.96% higher than the current per diem rates.</p><img src="/sites/default/files/inline-images/image_73.png" data-entity-uuid="e2187ce0-6ce1-49ab-9710-5375285244ee" data-entity-type="file" alt="Table 3 image" width="1017" height="544"><p>Five of the six component per-diem payment rates listed above are adjusted by case mix in determining the payment for a specific patient. Table 5 and 6 below, reproduced from the proposed rule, provide CMS’ proposed updated case-mix weights and resulting adjusted payment for each PDPM grouping. Table 5 provides the figures for urban facilities, and Table 6 provides the information for rural facilities.</p><img src="/sites/default/files/inline-images/image_76.png" data-entity-uuid="e1f36db5-ec81-4783-bdf4-f610db6ea707" data-entity-type="file" width="1117" height="511"><img src="/sites/default/files/inline-images/image_80.png" data-entity-uuid="3e24f506-2245-4a80-8d8b-7e0ed7199668" data-entity-type="file" alt="TABLE 6" width="1178" height="508"><p><strong>Wage Index Update</strong>s. CMS uses wage indexes to adjust SNF payments regionally to account for variation in labor cost. To do this, it utilizes core-based statistical areas (CBSAs) established by the Office of Management and Budget (OMB). Each county or county equivalent is assigned to a CBSA, and each CBSA is assigned a wage index. CBSAs are also designated as either urban or rural. A rural state-wide index applies to all rural facilities in a state. In July 2023, OMB issued <a href="https://www.whitehouse.gov/wp-content/uploads/2023/07/OMB-Bulletin-23-01.pdf" target="_blank" title="OMB Bulletin">a bulletin</a> that updated the CBSAs, and CMS proposes continuing to utilize the CBSAs from this update.</p><p>Wage indexes fluctuate from year to year based upon updated data presented to CMS. However, the agency has an existing policy of applying a 5% year-to-year cap on any reductions in an individual SNF’s wage index. CMS also applies a budget neutrality factor based on the estimated effects of updates to the wage indexes. This year, CMS proposes a budget neutrality factor of 1.0016, or 0.16%.</p><p><strong>Labor-related Share</strong>. The labor-related share is the portion of payment that is adjusted by the area wage index. The agency proposes a small decrease to this labor-related share, from 72.0% to 71.9%.</p><p><strong>PDPM ICD-10 Code Mappings</strong>. Under the PDPM, CMS uses patients’ primary ICD-10 diagnoses to classify them into certain clinical categories for purposes of the physical therapy (PT), occupational therapy (OT), speech-language pathology (SLP) and non-therapy ancillary (NTA) component payments. In this rule, the agency proposes changing the category to which certain ICD-10 codes are mapped, including Type 1 diabetes mellitus, hypoglycemia, obesity, anorexia nervosa, bulimia nervosa, binge eating disorder and pica. Specifically, it would change these codes from the Medical Management category to the Return to Provider category. CMS says these diagnoses would not be adequate justification for a covered Part A SNF stay and therefore should not be grouped into the Medical Management category. CMS also proposes reassigning serotonin syndrome from the Acute Neurologic to the Medical Management category.</p><p><strong>Request for Comment on Items and Services to be Excluded from Consolidated Billing</strong>. CMS generally requires all services provided to a SNF beneficiary during a covered stay to be consolidated and submitted by the SNF to its Medicare administrative contractor. SNFs are only permitted to separately bill for items and services that fall within certain categories — generally high-cost, low-frequency services that would place a financial hardship on a SNF if included in its standard payment. In an effort to update these excluded services, CMS is seeking comment on specific codes in the five permitted categories — chemotherapy items, chemotherapy administration services, radioisotope services, customized prosthetic devices and blood clotting factors — that would fit these criteria and are not already included on the excluded services list.</p><h2>SNF QUALITY REPORTING PROGRAM</h2><p>As mandated by the Affordable Care Act, SNFs receiving Medicare payments have been required to participate in the SNF QRP since 2014. The Improving Medicare Post-Acute Care Transformation (IMPACT) Act required that, starting FY 2019, providers must report standardized patient assessment data elements (SPADEs) as part of the SNF QRP. Failure to comply with these requirements results in a 2-percentage point reduction to the SNF’s annual market basket update.</p><p>CMS did not propose to adopt, modify or remove any measures from the SNF QRP. For FY 2026, the SNF QRP will comprise 14 measures based on updates to the QRP in previous rulemaking.</p><p><strong>Table 1: Previously Finalized Measures for the SNF QRP, FY 2024-FY</strong></p><div align="center"><table border="1" cellspacing="0" cellpadding="0" width="708"><thead><tr><th width="120"><p class="text-align-center"><strong>Data Source</strong></p></th><th width="360"><p class="text-align-center"><strong>Measure</strong></p></th><th width="76"><p class="text-align-center"><strong>FY 2024</strong></p></th><th width="76"><p class="text-align-center"><strong>FY 2025</strong></p></th><th width="76"><p class="text-align-center"><strong>FY 2026</strong></p></th></tr></thead><tbody><tr><td rowspan="2" width="120">National Healthcare Safety Network</td><td width="360">COVID-19 Vaccination Coverage Among Health Care Personnel</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Influenza Vaccination Coverage Among Health Care Personnel</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td rowspan="12" width="120">SNF Minimum Data Set</td><td width="360">Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay)</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function</td><td width="76">X</td><td width="76"><p class="text-align-center"> </p></td><td width="76"><p class="text-align-center"> </p></td></tr><tr><td width="360">Change in Self-Care Score for Medical Rehabilitation Patients</td><td width="76">X</td><td width="76"><p class="text-align-center"> </p></td><td width="76"><p class="text-align-center"> </p></td></tr><tr><td width="360">Change in Mobility Score for Medical Rehabilitation Patients</td><td width="76">X</td><td width="76"><p class="text-align-center"> </p></td><td width="76"><p class="text-align-center"> </p></td></tr><tr><td width="360">Discharge Self-Care Score for Medical Rehabilitation Patients</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Discharge Mobility Score for Medical Rehabilitation Patients</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Drug Regimen Review Conducted with Follow-up for Identified Issues</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Transfer of Health Information to Provider</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Transfer of Health Information to Patient</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Percent of Patients/Residents Who Are Up to Date with COVID-19 Vaccination</td><td width="76"> </td><td width="76"> </td><td width="76">X</td></tr><tr><td width="360">Discharge Function Score</td><td width="76"> </td><td width="76">X</td><td width="76">X</td></tr><tr><td rowspan="4" width="120">Claims</td><td width="360">Medicare Spending Per Beneficiary for Post-Acute Care SNF QRP</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Discharge to Community</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">Potentially Preventable 30-day Post-discharge Readmission Measure</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr><tr><td width="360">SNF Healthcare-associated Infections Requiring Hospitalization</td><td width="76">X</td><td width="76">X</td><td width="76">X</td></tr></tbody></table></div><p>X=Measure required for reporting</p><p><strong>Proposed Removal of Four Social Determinants of Health (SDOH) SPADEs. </strong>Beginning with the FY 2027 SNF QRP, CMS proposes to remove four new SPADEs under the SDOH category. This category was finalized in the FY/CY 2020 final rules for the inpatient rehabilitation facility, SNF, LTCH and home health QRPs, and currently comprises SPADEs addressing the following topics:</p><ul type="disc"><li>Race.</li><li>Ethnicity.</li><li>Preferred language.</li><li>Interpreter services.</li><li>Health literacy.</li><li>Social isolation.</li><li>Transportation.</li></ul><p>With a stated purpose of reducing administrative burden to SNFs, CMS proposes removing four SPADEs it adopted in the FY 2025 SNF PPS final rule that are focused on:</p><ul><li>Living situation.</li><li>Food security.</li><li>Utilities.</li></ul><p><strong>Reconsideration Process. </strong>Most CMS quality reporting and value programs — including the SNF QRP — include a reconsideration process permitting providers to appeal a CMS initial determination of noncompliance with reporting or other programmatic requirements. CMS proposes allowing SNFs to request an extension to file a request for reconsideration in the event the organization experiences an extraordinary circumstance (e.g., natural disaster) that overlaps with the deadline for filing a reconsideration request.</p><p>Secondly, CMS proposes clarifying the basis on which the agency can grant a reconsideration request and reverse an initial determination of noncompliance. Specifically, CMS would reverse a finding of noncompliance only if it determines that the SNF was in full compliance with the SNF QRP requirements for the applicable program year, including following CMS’ established policies for requesting and receiving an extraordinary circumstance exception from reporting.</p><p><strong>Request for Information.</strong> The proposed rule includes requests for information on three key areas. First, CMS asks for input on new measure concepts focused on interoperability, well-being, nutrition and delirium. Second, CMS seeks input on how to advance the uptake of digital quality measures in the SNF QRP. CMS is particularly interested in the extent to which SNFs are using application programming interfaces based on the Fast Healthcare Interoperability Resource (FHIR) standard to support any data reporting or exchange functions.  Third, the agency seeks input on decreasing the amount of time that SNFs have to submit quarterly quality measure and SPADE data to CMS. Currently, SNFs have four and a half months after a quarter closes to submit data to CMS. CMS seeks input on potentially requiring that quality and SPADE data be submitted 45 days after the close of a quarter. The agency believes this would result in more timely publicly-reported data on SNF performance.</p><h2>SNF VALUE-BASED PURCHASING PROGRAM</h2><p>Please see AHA’s FY 2024 <a href="/2023-08-21-skilled-nursing-facility-pps-final-rule-fy-2024" target="_blank" title="AHA regulatory advisory">Regulatory Advisory</a> for the most recent updates to the SNF VBP Program, including the adoption of four new quality measures and several policy changes.</p><p><strong>Table 2. Previously Finalized SNF VBP Measures</strong></p><table border="1" cellspacing="0" cellpadding="0"><tbody><tr><td width="250"><strong>Measure</strong></td><td width="70"><strong>FY 25</strong></td><td width="70"><strong>FY 26</strong></td><td width="70"><strong>FY 27</strong></td><td width="70"><strong>FY 28</strong></td><td width="94"><strong>Used in SNF QRP?</strong></td></tr><tr><td width="250">SNF 30-Day All-Cause Readmissions</td><td width="70">X</td><td width="70">X</td><td width="70">X</td><td width="70"> </td><td width="94">No</td></tr><tr><td width="250">SNF Healthcare-associated Infections Requiring Hospitalization</td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="70">X</td><td width="94">Yes</td></tr><tr><td width="250">Total Nurse Staffing Hours per Resident Day</td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="70">X</td><td width="94">No</td></tr><tr><td width="250">Total Nursing Staff Turnover</td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="70">X</td><td width="94">No</td></tr><tr><td width="250">Discharge to Community</td><td width="70"> </td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="94">Yes</td></tr><tr><td width="250">Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay)</td><td width="70"> </td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="94">Similar</td></tr><tr><td width="250">Discharge Function Score</td><td width="70"> </td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="94">Yes</td></tr><tr><td width="250">Number of Hospitalizations per 1,000 Long Stay Resident Days</td><td width="70"> </td><td width="70"> </td><td width="70">X</td><td width="70">X</td><td width="94">No</td></tr><tr><td width="250">SNF Within-Stay Potentially Preventable Readmissions</td><td width="70"> </td><td width="70"> </td><td width="70"> </td><td width="70">X</td><td width="94">No</td></tr></tbody></table><p><strong>Removal of Health Equity Adjustment. </strong>Beginning with the FY 2027 SNF VBP program, CMS proposes to remove the health equity adjustment from the SNF VBP scoring methodology. The health equity adjustment awarded bonus points to SNFs based on a combination of quality performance and proportion of dual-eligible patients cared for by SNFs. CMS believes that the removal of the adjustment would simplify program scoring and “provide clearer incentives to hospitals as they seek to improve the quality of care for all patients.” CMS also believes the impact of the adjustment would be small.</p><p><strong>REQUEST FOR INFORMATION: EXECUTIVE ORDER 14192 “UNLEASHING PROSPERITY THROUGH DEREGULATION”</strong></p><p>On Jan. 31, 2025, President Trump issued Executive Order (EO) 14192, "Unleashing Prosperity Through Deregulation," which states the administration’s policy to significantly reduce the private expenditures required to comply with federal regulations. Accordingly, CMS is soliciting public input on approaches and opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program. CMS is collecting responses at <a href="https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.cms.gov%2Fmedicare-regulatory-relief-rfi&data=05%7C02%7Cjgold%40aha.org%7C4cd60274604142c4278308dd7b7460c2%7Cb9119340beb74e5e84b23cc18f7b36a6%7C0%7C0%7C638802461951091442%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=oVpGbZYA%2Bop4qTxZ4eXdtgj417%2BP2swWi8qUj%2FsAsYw%3D&reserved=0" title="Original URL: https://www.cms.gov/medicare-regulatory-relief-rfi. Click or tap if you trust this link.">https://www.cms.gov/medicare-regulatory-relief-rfi</a> and requests stakeholders submit comments through the provided web link by June 10.</p><h2>FURTHER QUESTIONS</h2><p>Please contact Jonathan Gold, the AHA’s senior associate director of policy, at <a href="mailto:jgold@aha.org">jgold@aha.org</a>, with any questions related to payment, and Akin Demehin, the AHA’s vice president of quality and safety policy, at <a href="mailto:ademehin@aha.org">ademehin@aha.org</a>, regarding any quality-related questions.</p></div><div class="col-md-4"><a href="/system/files/media/file/2025/05/skilled-nursing-facility-pps-proposed-rule-for-fy-2026-advisory-5-15-2025.pdf"><img src="/sites/default/files/2025-05/cover-skilled-nursing-facility-pps-proposed-rule-for-fy-2026-advisory-5-15-2025.png" data-entity-uuid data-entity-type="file" alt="Advisory Cover Image" width="NaN" height="NaN"></a></div></div></div> Thu, 15 May 2025 16:18:03 -0500 Skilled Nursing Facility PPS /2025-04-14-cms-releases-fy-2026-skilled-nursing-facility-pps-proposed-rule <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) April 11 issued its fiscal year (FY) 2026 <a href="https://www.federalregister.gov/public-inspection/2025-06348/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities">proposed rule</a> for the skilled nursing facility (SNF) prospective payment system (PPS).</p><div class="panel module-typeC"><div class="panel-heading"><p>Key highlights</p><p>The proposed rule would:</p><ul><li>Increase aggregate SNF payments by an estimated 2.8% ($997 million) in FY 2026 relative to FY 2025.</li><li>Make technical changes to its Patient-Driven Payment Model (PDPM) ICD-10 code mapping that assigns patients to clinical categories.</li><li>For the SNF quality reporting program (QRP), remove four patient assessment data elements.</li><li>For the SNF value-based purchasing program (VBP), remove the program’s health equity adjustment.</li></ul></div></div><h2>AHA Take</h2><p>The AHA appreciates the relatively straightforward rulemaking, including the request for information on burden reduction for providers. However, the AHA continues to be concerned about the lower-than-needed market basket updates and lagging forecast error adjustments.</p><p>Highlights from the rule follow.</p><h2>PROPOSED SNF PPS PAYMENT CHANGES</h2><p>The rule’s proposed annual update would increase net payments to SNFs by an estimated 2.8% ($997 million) in FY 2026 relative to FY 2025. This includes a 3.0% market-basket update offset by a statutorily mandated productivity cut of 0.8% and a 0.6% market-basket forecast error adjustment for FY 2024.</p><p>CMS also proposes technical changes to its PDPM ICD-10 code mapping that assigns patients to clinical categories. These proposed changes can be found on <a href="https://www.cms.gov/medicare/payment/prospective-payment-systems/skilled-nursing-facility-snf/list-federal-regulations/cms-1827-p">CMS’ site</a> for this rulemaking. </p><p><strong>SNF QUALITY REPORTING PROGRAM AND VALUE-BASED PURCHASING PROGRAM </strong></p><p><u>SNF QRP.</u> Beginning with the reporting period starting Oct. 1, 2025, CMS proposes to make optional the reporting of four standardized patient assessment data elements in the Minimum Data Set focused on social determinants of health. This includes one item focused on living situation, two items focused on food insecurity and one item focused on utilities.</p><p>CMS also asks for input on future SNF QRP measure concepts and advancing digital quality measures in the SNF QRP.</p><p><u>SNF VBP Program.</u> CMS proposes to remove the program’s health equity adjustment that otherwise would be in effect beginning FY 2027. The health equity adjustment would award bonus points to SNFs based on a combination of their quality performance and the proportion of patients dually eligible for Medicare and Medicaid.</p><p><strong>REQUEST FOR INFORMATION: UNLEASHING PROSPERITY THROUGH DEREGULATION OF THE MEDICARE PROGRAM (EXECUTIVE ORDER 14192)</strong></p><p>On Jan.31, 2025, President Trump issued Executive Order (EO) 14192, "Unleashing Prosperity Through Deregulation," which states the administration’s policy to significantly reduce the private expenditures required to comply with federal regulations. CMS would like public input on approaches and opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program. The agency has made available an RFI at <a href="https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.cms.gov%2Fmedicare-regulatory-relief-rfi&data=05%7C02%7Cjgold%40aha.org%7C4cd60274604142c4278308dd7b7460c2%7Cb9119340beb74e5e84b23cc18f7b36a6%7C0%7C0%7C638802461951091442%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=oVpGbZYA%2Bop4qTxZ4eXdtgj417%2BP2swWi8qUj%2FsAsYw%3D&reserved=0" target="_blank" title="Original URL: https://www.cms.gov/medicare-regulatory-relief-rfi. Click or tap if you trust this link.">https://www.cms.gov/medicare-regulatory-relief-rfi</a> and requests stakeholders to submit all comments in response to this RFI through the provided web link.</p><h2>NEXT STEPS</h2><p>CMS will accept comments on the SNF PPS proposed rule through June 10.</p><p>Please contact Jonathan Gold, AHA’s senior associate director of policy, at <a href="mailto:jgold@aha.org">jgold@aha.org</a>, with any questions related to payment, and Akin Demehin, AHA’s vice president of quality and safety policy, at <a href="mailto:ademehin@aha.org">ademehin@aha.org</a>, regarding any quality-related questions.</p></div><div class="col-md-4"><a href="/system/files/media/file/2025/04/cms-releases-fy-2026-skilled-nursing-facility-pps-proposed-rule-advisory-4-14-2025.pdf"><img src="/sites/default/files/2025-04/cover-cms-releases-fy-2026-skilled-nursing-facility-pps-proposed-rule-advisory-4-14-2025-r.png" data-entity-uuid data-entity-type="file" alt="Cover Image of SNF Advisory" width="640" height="828"></a></div></div></div> Mon, 14 Apr 2025 17:13:38 -0500 Skilled Nursing Facility PPS /news/headline/2025-04-11-cms-proposes-28-payment-update-snfs <p>The Centers for Medicare & Medicaid Services April 11 issued a proposed rule for the <a href="https://www.federalregister.gov/public-inspection/2025-06348/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities">skilled nursing facility</a> prospective payment system for fiscal year 2026. The proposal would increase aggregate payments by 2.8%, which reflects a 3.0% market basket update, a 0.8 percentage point cut for productivity, and an increase of 0.6 percentage points for the market basket forecast error for FY 2024. CMS also is proposing changes to some ICD-10 code mappings for payment classifications. In addition, it has included in the rule its previously published request for information seeking input on opportunities to streamline regulations and reduce burdens on providers. <br> <br>For the SNF Quality Reporting Program, CMS proposes to remove four patient assessment data elements. CMS also asks for input on future SNF QRP measure concepts and advancing digital quality measures in the SNF QRP. For the SNF value-based payment program, CMS proposes to remove the program’s health equity adjustment. <br> <br>CMS will accept public comments on the proposed rule through June 10. AHA members will receive a Regulatory Advisory with additional information. </p> Fri, 11 Apr 2025 18:23:01 -0500 Skilled Nursing Facility PPS /testimony/2025-03-11-aha-statement-house-ways-and-means-subcommittee-health-hearing-march-11-2025 <div class="container"><div class="row"><div class="col-md-8"><h2>Statement<br>of the<br>���������� Association<br>for the<br>Committee on Ways and Means<br>Subcommittee on Health<br>of the<br>U.S. House of Representatives<br>“After the Hospital: Ensuring Access to Quality Post-Acute Care”<br>March 11, 2025</h2><p>On behalf of our nearly 5,000 member hospitals and health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and our 2,425 post-acute care members, the ���������� Association (AHA) appreciates the opportunity to submit this statement for the record to the Ways and Means Subcommittee on Health on the value of post-acute care and how Congress can better support patients’ access to these critical services.</p><h2>General Policy & Regulatory Challenges</h2><p>Post-acute care is provided to patients who have been discharged from an acute-care hospital but still require services such as close medical supervision, nursing care, therapies and other support. Long-term care hospitals (LTCHs) act as a pressure relief valve for high-acuity patients needing extended hospital stays, thereby easing the burden on intensive care units (ICUs). Inpatient rehabilitation facilities (IRFs) assist patients recovering from life-changing illnesses like brain injuries, spinal cord injuries and amputations. Skilled nursing facilities (SNFs) offer rehabilitation therapy services aimed at strengthening patients and making them more independent before they return home. Home health agencies (HHs) enable seniors to remain independent by providing medical or non-medical care in their homes. Each of these facilities plays a crucial role across the continuum of care.</p><p>While each specific post-acute sector faces unique challenges, there are several policy and regulatory issues that are universal.</p><h3>Medicare Advantage</h3><p>Medicare Advantage (MA) plans are an increasingly popular choice for older Americans, and measures must be taken to ensure that patients who require post-acute care services are able to access them in a timely manner. Perhaps the biggest challenge facing post-acute care providers and their patients is the ongoing restrictions that MA plans place on access to care. The issue has been well documented by providers as well as by Department of Health and Human Services Office of Inspector General and congressional investigations.<a href="#fn1"><sup>1</sup></a><sup>,</sup><a href="#fn2"><sup>2</sup></a> The prior authorization process used by MA plans places significant administrative burden on both acute-care hospitals and post-acute care providers. Perhaps more importantly, it is directly harmful to Medicare beneficiaries — at best delaying their care and at worst outright denying medically necessary treatment.</p><p>MA plans’ practices have directly contributed to the growing discharge delay problems plaguing acute-care hospitals. While all beneficiaries have faced these delays, the increase in length of stay for MA beneficiaries seeking post-acute care has increased twice as much compared to Traditional Medicare beneficiaries. Specifically, the average length of stay (ALOS) prior to discharge to post-acute care settings has grown by 11.3% for MA patients between 2019 and 2024. However, for patients in Traditional Medicare, the ALOS has grown by only 5.2%, according to industry benchmark data from Strata Decision Technology, LLC.</p><p>Despite steps taken by the Centers for Medicare & Medicaid Services (CMS) in recent years, providers have seen little to no meaningful change in MA plan behavior and no increased access for beneficiaries. Additionally, post-acute care providers still face challenges with MA plans listing them within their networks. CMS should conduct regular audits to ensure that MA plans include robust post-acute care options with sufficient bed spaces and resources to provide the in-network care that patients need. As MA enrollment continues to grow, it is imperative that Congress continue to rein in these harmful practices to ensure that beneficiaries are not denied the care to which they are entitled.</p><h3>Ongoing Workforce Challenges</h3><p>The U.S. health care system is facing unprecedented workforce shortages, with the Bureau of Labor Statics estimating there will be 193,100 openings for nurses in each of the next 10 years.<a href="#fn3"><sup>3</sup></a> For physicians, there could be a shortage of between 37,800 and 124,000 physicians by 2034 for both primary and specialty care.<a href="#fn4"><sup>4</sup></a> Since mid-2020, post-acute care providers have seen a significant number of patient care technicians, registered nurses, and respiratory therapists, among other vital professionals, shifting employment to other organizations. Some post-acute care providers in rural areas have experienced significant challenges in filling open positions, sometimes going months without receiving an application for open registered nurses, licensed practical nurses, certified nursing assistants or key leadership roles. Staffing challenges jeopardize the ability of seniors to access the care they need and deserve.</p><p>To ensure residents and families have access to high-quality care close to home, meaningful, long-term solutions and investments in workforce development must replace stop-gap measures, reimbursement cuts and punitive regulations. The AHA encourages Congress to pass the Conrad State 30 and Physician Access Reauthorization Act (S.709/H.R.1585) and the Healthcare Workforce Resilience Act, as well as support visa recapture initiatives and continue support for the Health Resources and Services Administration’s (HRSA) health professions and nursing workforce development programs.</p><h2>Sector Specific Comments</h2><h3>Long-Term Care Hospitals</h3><p>LTCHs play a unique role for Medicare and other beneficiaries by caring for the most severely ill patients who require extended hospitalization. LTCHs offer an intensive, hospital-level of care that may not be available in other post-acute care settings. LTCH patients are typically very medically complex, with multiple organ failures, and stay in LTCHs on average for at least 25 days. Many LTCH patients depend on ventilators due to respiratory failure or similar ailments, which require highly specialized care and extended stays. In addition, LTCHs are critical partners for acute-care hospitals, alleviating capacity for overburdened ICUs and other parts of the care continuum that would otherwise be further strained without access to LTCHs for these patients.</p><p>In 2016, Congress put in place a dual-rate payment system under the LTCH prospective payment system (PPS) for Traditional Medicare beneficiaries.<a href="#fn5"><sup>5</sup></a> This fundamental change in the payment system and other coinciding market factors dramatically reshaped the landscape of both LTCHs and the beneficiaries they serve. Since implementation of the dual-rate payment system, the volume of standard LTCH cases has fallen by approximately 70% from its peak under the legacy payment system and the number of LTCH providers also has decreased by 20%. At the same time, the average acuity of LTCH patients has risen by 20% or more in that same period, and these patients are increasingly consolidated into a limited number of Diagnosis-Related Groups (DRGs).<a href="#fn6"><sup>6</sup></a> In addition, approximately one-third of all Medicare LTCH discharges nationally are paid the inpatient PPS-equivalent rate. However, these reimbursements fall well short of the cost of care. AHA’s analysis shows that as of fiscal year 2020 reimbursement for these cases totaled only 46% of the cost of care.<a href="#fn7"><sup>7</sup></a> Finally, the growth of MA has further shrunk the patient population for LTCHs as MA plans routinely inappropriately deny access to LTCHs.</p><p>The smaller, sicker patient population and dwindling reimbursement has created many challenges for LTCHs, as evidenced by the closure of so many of these facilities. The remaining patient pool is notably more acute and costly to treat, resulting in cases increasingly qualifying for high-cost outlier (HCO) payments to compensate for lack of precision in the DRGs as so many cases are consolidated into a limited number of DRGs. In 2016, the fixed-loss amount (FLA) for HCO cases, which is the amount of financial loss an LTCH must incur before qualifying for an HCO payment, was $16,423. Since that time, the FLA has risen by more than 300% to $77,048. This unsustainable figure puts LTCHs in the untenable position of having to lose tens of thousands of dollars in order to care for some of the sickest patients. Unfortunately, CMS has been unable to deviate from its current methodology to provide relief from this policy due to a congressional mandate to cap total outlier payments at 8% of total payments.<a href="#fn8"><sup>8</sup></a></p><p>The AHA appreciates this Subcommittee’s awareness of the need to provide relief to the LTCH sector and supports efforts to provide additional flexibility and funding for HCO cases, and additional flexibility to provide care for different types of patients through the standard payment system.</p><h3>Inpatient Rehabilitation Facilities</h3><p>IRF patients are typically admitted directly from an acute-care hospital following a serious accident or illness such as stroke, brain injury, amputation or others that have resulted in serious functional deficits and medical complications. IRFs provide hospital-level care, which means they are closely supervised by a physician who also oversees patients’ overall rehabilitation. The intensive course of rehabilitation provided in IRFs must include a minimum of 15 hours per week of intensive therapy services involving multiple therapy disciplines, as well as around-the-clock specialized nursing care. This level of care is critical for debilitated patients who are stable enough to be discharged from the acute-care hospital to begin intensive rehabilitation but are at risk for medical complications without continued close medical management.</p><p>The AHA continues to hear from IRFs regarding their concerns with CMS’ IRF Review Choice Demonstration (RCD). CMS initially created the IRF RCD to “assist in developing improved procedures for the identification, investigation, and prosecution of potential Medicare fraud.” However, the agency never provided credible evidence to support its belief that there may be high rates of fraud in the IRF field — it only cited its improper payment rate for IRFs, which, as it knows, is not the same as fraud. Since being operationalized by the Biden administration in 2023, CMS has not subsequently provided any evidence that the IRF RCD has revealed or assisted in uncovering any fraud. Specifically, the demonstration currently subjects 100% of IRF claims to review in both Alabama and Pennsylvania. Yet, according to CMS’ <a href="https://www.cms.gov/files/document/irf-rcd-stats-fy-2024.pdf" target="_blank" title="CMS: Review Choice Demonstration for Inpatient Rehabilitation Facility Services (IRF RCD) Quarterly Updates. Fiscal Year 2024 (Oct 2023 – Sept 2024).">most recent data</a> collected during fiscal year 2024, approximately 90% of all claims reviewed have been approved. Of those, more than 95% were approved on the initial submission. Despite this high affirmation rate and lack of evidence of any fraud, CMS says it still plans to continue its expansion of the demonstration to more than half of all states and territories, subjecting hundreds of thousands of IRF claims annually to the burdensome manual medical review process. It has become clear that this demonstration is burdensome, diverts valuable clinical resources, and is not achieving its stated objective of uncovering or preventing fraud in the Medicare program.</p><p>Therefore, the continued need for the IRF RCD remains highly dubious, and the AHA continues to encourage CMS and Congress to end this program.</p><h3>Skilled Nursing Facilities</h3><p>SNFs play another critical role for many hospitalized patients who need continued care after discharge. However, hospitals have faced increasing difficulty discharging patients to post-acute care settings, including SNFs. This challenge has largely been due to staffing shortages and the associated reduced capacity of SNFs and other providers. These shortfalls then place additional burden back on hospitals, including the need for hospitals to board patients until a discharge location can be found. Therefore, it is vital for the entire continuum of care, including for acute-care hospitals, that SNFs are properly resourced.</p><p>The AHA and its members are committed to safe staffing to ensure high-quality, patient-centered care in all health care settings, including long-term care (LTC) facilities. Yet, the process of safely staffing any health care facility is about much more than achieving an arbitrary number set by regulation. It requires clinical judgment and flexibility to account for patient needs, facility characteristics, and the expertise and experience of the care team. The Biden administration’s one-size-fits-all minimum staffing rule for LTC facilities creates more problems than it solves and could jeopardize access to all types of care across the continuum, especially in rural and underserved communities that may not have the workforce levels to support these requirements.</p><p>The AHA supports the Protecting America’s Seniors Access to Care Act (H.R. 1683) to prohibit the Department of Health and Human Services from implementing the provisions of the minimum staffing rule. We have recommended to CMS specific alternative strategies that take more patient- and workforce-centered approaches to ensuring LTC facilities have a strong foundation of policies and processes to continually assess, reassess and adjust their staffing levels. These strategies constitute starting points for further standards development, which we would encourage CMS to engage in with the assistance of patients and the entire health care continuum. Not only would these proposed alternatives support more timely and effective action by LTC facilities to address staffing challenges, but they also would be more consistent with modern clinical practice. Thus, repealing the Biden-era mandate would both protect patient access to care and allow for the development of more effective and clinically appropriate strategies to improve LTC patient outcomes.</p><h3>Home Health Agencies</h3><p>Approximately one in five hospitalized Medicare beneficiaries are discharged to HH.<a href="#fn9"><sup>9</sup></a> These services alleviate pressure on hospitals, other post-acute care sites and caregivers, who would otherwise be responsible for these patients. HH agencies also can prevent rehospitalization by safely providing needed interventions at home thus avoiding potential complications and accidents.</p><p>Over the last few years, the AHA has seen a strain on HH operations — along with other post-acute care providers — due to financial challenges, creating ripple effects throughout the continuum of care. Hospitals have seen the length of stay for patients being discharged to HH increase as they face increasing difficulty finding placements for these patients.<a href="#fn10"><sup>10</sup></a> This has been due in large part to the reductions in reimbursement to HH providers put in place by CMS since its implementation of the new Medicare fee-for-service payment system in 2020. CMS determined it must permanently cut HH payments from between 4% to 8% annually in order to meet statutory budget neutrality requirements. In addition, CMS has indicated that it intends to recoup billions more in temporary reductions in the coming years. These payment reductions, paired with staffing shortages, and other administrative burdens and costs will continue to have serious implications for access to services for Medicare beneficiaries. The AHA is thankful for the Committee’s ongoing support of home health agencies.</p><h2>Conclusion</h2><p>Thank you for your leadership on these important issues and for the opportunity to provide comments. We look forward to continuing to work with you to address these important topics on behalf of our patients and communities.</p><hr><ol><li id="fn1">HHS, Office of Inspector General (OIG); Some Medicare Advantage Organization Denials of Prior Authorization Requests Raise Concerns About Beneficiary Access to Medically Necessary Care (April 2022) (<a href="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf" target="_blank">https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf</a>).</li><li id="fn2"><a href="https://www.hsgac.senate.gov/wp-content/uploads/2024.10.17-PSI-Majority-Staff-Report-on-Medicare-Advantage.pdf" target="_blank">https://www.hsgac.senate.gov/wp-content/uploads/2024.10.17-PSI-Majority-Staff-Report-on-Medicare-Advantage.pdf</a>.</li><li id="fn3">3<a href="https://www.bls.gov/ooh/healthcare/registered-nurses.htm#tab-6" target="_blank">https://www.bls.gov/ooh/healthcare/registered-nurses.htm#tab-6</a>.</li><li id="fn4">4<a href="https://www.aamc.org/news/press-releases/aamc-report-reinforces-mounting-physician-shortage" target="_blank">https://www.aamc.org/news/press-releases/aamc-report-reinforces-mounting-physician-shortage</a>.</li><li id="fn5">Bipartisan Budget Act Of 2013 (P.L. 113–67).</li><li id="fn6"><a href="/white-papers/2023-12-29-white-paper-medicares-ltch-outlier-policy-needs-reforms-protect-extremely-ill-beneficiaries" target="_blank">/white-papers/2023-12-29-white-paper-medicares-ltch-outlier-policy-needs-reforms-protect-extremely-ill-beneficiaries</a>.</li><li id="fn7"><a href="/system/files/media/file/2019/06/aha-cms-long-term-care-proposed-rule-fy2020-6-21-2019_0.pdf" target="_blank">/system/files/media/file/2019/06/aha-cms-long-term-care-proposed-rule-fy2020-6-21-2019_0.pdf</a>.</li><li id="fn8">Section 15009(b) of the 21ST Century Cures Act added section 1886(m)(7) to the Act.</li><li id="fn9">MedPAC; July 2024 Data Book; Section 8, Pg. 107 (<a href="https://www.medpac.gov/wp-content/uploads/2024/07/July2024_MedPAC_DataBook_Sec8_SEC.pdf" target="_blank">https://www.medpac.gov/wp-content/uploads/2024/07/July2024_MedPAC_DataBook_Sec8_SEC.pdf</a>).</li><li id="fn10"><a href="/lettercomment/2024-08-26-aha-comments-calendar-year-2025-home-health-prospective-payment-system-proposed-rule" target="_blank">/lettercomment/2024-08-26-aha-comments-calendar-year-2025-home-health-prospective-payment-system-proposed-rule</a>.</li></ol></div><div class="col-md-4"><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/03/AHA-Statement-to-House-Ways-and-Means-Subcommittee-on-Health-for-Hearing-March-11-2025.pdf" target="_blank" title="Click here to download the AHA Statement to House Ways and Means Subcommittee on Health for Hearing March 11, 2025 PDF.">Download the Testimony PDF</a></div><a href="/system/files/media/file/2025/03/AHA-Statement-to-House-Ways-and-Means-Subcommittee-on-Health-for-Hearing-March-11-2025.pdf"><img src="/sites/default/files/inline-images/Page-1-AHA-Statement-to-House-Ways-and-Means-Subcommittee-on-Health-for-Hearing-March-11-2025.png" data-entity-uuid="ef5df51a-efdf-417b-bd24-197ee16b5607" data-entity-type="file" alt="AHA Statement to House Ways and Means Subcommittee on Health for Hearing March 11, 2025 page 1." width="695" height="900"></a></div></div></div> Tue, 11 Mar 2025 12:52:15 -0500 Skilled Nursing Facility PPS /advisory/2024-08-27-skilled-nursing-facility-prospective-payment-system-final-rule-fy-2025 <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) July 31 <a href="https://www.federalregister.gov/documents/2024/04/03/2024-06812/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities">issued</a> its fiscal year (FY) 2025 final rule for the skilled nursing facility (SNF) prospective payment system (PPS). This rule updates SNF payments and modifies CMS’ nursing home enforcement authority and the SNF Quality Reporting Program (QRP) measures and reporting requirements</p><div class="panel module-typeC"><div class="panel-heading"><h2>Key Highlights</h2><p>The rule will: </p><ul><li>Increase aggregate SNF payments by an estimated 4.2% ($1.4 billion) in FY 2025 relative to FY 2024. This includes a:<ul><li>3.0% market basket update reduced by a 0.5% productivity cut.</li><li>1.7% increase due to FY 2023 market basket forecast error.</li></ul></li><li>Make technical changes to its Patient-Driven Payment Model (PDPM) ICD-10 code mapping that assigns patients to clinical categories.</li><li>Revise CMS nursing home enforcement authority to allow the agency to impose multiple financial penalties on nursing homes with safety deficiencies.</li><li>Adopt and modify patient assessment items addressing social determinants of health (SDOH).</li></ul></div></div><h2>AHA TAKE</h2><p>While the AHA appreciates the intent of the changes CMS makes to its enforcement authority, we remain concerned that tying increased civil monetary penalties (CMPs) to the imperfect survey process will disadvantage smaller or lower-resourced facilities. We will encourage the agency both to continue to look for ways to improve the survey process and to use discretion in enforcing penalties based on instances of noncompliance with the newly finalized long-term care staffing standards.</p></div><div class="col-md-4"><a href="/system/files/media/file/2024/08/skilled-nursing-facility-prospective-payment-system-final-rule-for-fy-2025-advisory-8-27-2024.pdf"><img data-entity-uuid="978624f2-f5e1-489d-8a89-9cb5f2cff728" data-entity-type="file" src="/sites/default/files/inline-images/cover-skilled-nursing-facility-prospective-payment-system-final-rule-for-fy-2025-advisory-8-27-2024.png" width="644" height="832" alt="Skilled Nursing Facility PPS Cover Image"></a></div></div></div> Tue, 27 Aug 2024 10:50:23 -0500 Skilled Nursing Facility PPS /2024-08-01-cms-releases-fy-2025-skilled-nursing-facility-pps-final-rule <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) July 31 issued its fiscal year (FY) 2025 <a href="https://www.federalregister.gov/public-inspection/2024-16907/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities" target="_blank" title="Final Rule">final rule</a> for the skilled nursing facility (SNF) prospective payment system (PPS). This rule updates SNF PPS payments</p><div class="panel module-typeC"><div class="panel-heading"><h2>Key Highlights</h2><p>The rule will:</p><ul><li>Increase aggregate SNF payments by an estimated 4.2% ($1.4 billion) in FY 2025 relative to FY 2024. This includes:<ul><li>3.0% market basket update reduced by a 0.5% productivity cut.</li><li>1.7% increase due to FY 2023 market basket forecast error.</li></ul></li><li>Make technical changes to its Patient Driven Payment Model (PDPM) ICD-10 code mapping that assigns patients to clinical categories.</li><li>Revise CMS nursing home enforcement authority to allow the agency to impose multiple financial penalties on nursing homes with safety deficiencies.</li><li>Adopt and modify patient assessment items addressing social determinants of health.</li></ul></div></div><h2>AHA TAKE </h2><p>While the AHA appreciates the intent of the changes CMS makes to its enforcement authority, we remain concern that tying increased civil monetary penalties (CMPs) to the imperfect survey process will disadvantage smaller or lower-resourced facilities. We will encourage the agency both to continue to look for ways to improve the survey process and to use discretion in enforcing penalties based on instances of noncompliance with the newly finalized long-term care staffing standards.</p><p>Highlights from the rule follow. </p><h2>SNF PPS PAYMENT CHANGES</h2><p>The rule increases net payments to SNFs by an estimated 4.2% ($1.4 billion) in FY 2025 relative to FY 2024. This includes a 3.0% market-basket update, a statutorily-mandated productivity cut of 0.5% and an increase of 1.7% due to the market basket forecast error in FY 2023. The 4.2% is slightly higher than the proposed amount of 4.1% due to a slightly higher market basket update.</p><p>CMS also finalized technical changes to its PDPM ICD-10 code mapping that assigns patients to clinical categories. These changes can be found on <a href="https://www.cms.gov/medicare/payment/prospective-payment-systems/skilled-nursing-facility-snf" title="Techincal changes">CMS’ site</a> for this rule.</p><p>Additionally, CMS finalized as proposed its rebasing and revising of the SNF market basket to reflect a 2022 base year. Finally, it implemented new wage indices to incorporate updated core-based statistical areas developed by the White House Office of Management and Budget.</p><h2>NURSING HOME ENFORCEMENT</h2><p>In an effort to enhance oversight of long-term care facilities, CMS finalized changes to its regulatory authority regarding the agency’s ability to impose CMPs on facilities demonstrating deficiencies in quality or safety. Under current regulations, CMS may assess penalties on a per day (PD) or per instance (PI) basis during a survey, but not both. However, the agency finalized its proposal to enable more types of CMPs to be imposed during a survey “to be better aligned with the noncompliance identified during the survey and for more consistency of CMP amount across the nation.” The amount of CMP will increase based on the severity and/or extent of harm.</p><h2>SNF QUALITY REPORTING PROGRAM </h2><p>CMS did not adopt, modify or remove any quality measures from the Quality Reporting Program (QRP) in this rule. </p><p>CMS finalized its proposal to require SNFs to report four new patient assessment items in the SNF Minimum Data Set (MDS) under the social determinants of health category beginning with the FY 2027 SNF QRP (that is, with admissions beginning on Oct. 1, 2025). The items are currently collected in the Accountable Health Communities Health-Related Social Needs Screening Tool, and include:</p><ul><li>Living situation: addresses housing stability.</li><li>Food: addresses frequency of worry that food would run out.</li><li>Food: addresses food running out without ability to buy more.</li><li>Utilities: addresses utilities being shut off in home.</li></ul><p>In addition, CMS will modify the patient assessment item on transportation to simplify the response options and revise the look-back period. </p><p>Finally, CMS will require SNFs to participate in a data validation process beginning with the FY 2027 SNF QRP, as required by the Consolidated Appropriations Act of 2021. Specifically, the agency adopts a similar validation process for the SNF QRP that is used in the SNF Value-based Purchasing (VBP) program for assessment-based quality measures.</p><h2>SNF VALUE-BASED PURCHASING PROGRAM </h2><p>CMS finalized a number of operational updates to the VBP program that revise regulatory language to account for changes adopted for the program in previous rulemaking (such as a measure retention policy that applies to the VBP measure set that was expanded in the FY 2024 SNF PPS final rule), as well as general program policies like an extraordinary circumstances exception process and review and corrections timeline.</p><h2>FURTHER QUESTIONS</h2><p>Please contact Jonathan Gold, AHA’s senior associate director of payment policy, at <a href="mailto:jgold@aha.org" title="Jpnathan Gold Email">jgold@aha.org</a>, with any questions related to payment, and Caitlin Gillooley, AHA’s director of policy, at <a href="mailto:cgillooley@aha.org">cgillooley@aha.org</a>, regarding any quality-related questions.</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2024/08/cms-releases-fy-2025-skilled-nursing-facility-pps-final-rule-bulletin-8-1-2024.pdf" target="_blank" title="Click here to download the Special Bulletin: CMS Releases FY 2025 Skilled Nursing Facility PPS Final Rule PDF."><img src="/sites/default/files/2024-08/cover-cms-releases-fy-2025-skilled-nursing-facility-pps-final-rule-bulletin-8-1-2024.png" data-entity-uuid data-entity-type="file" alt="Special Bulletin: CMS Releases FY 2025 Skilled Nursing Facility PPS Final Rule cover." width="NaN" height="NaN"></a></p></div></div></div> Thu, 01 Aug 2024 16:14:12 -0500 Skilled Nursing Facility PPS