Proposed Rule SNF FY 2025 PPS Top 5 Things to Know

Proposed Rule SNF FY 2025 PPS 

Top 5 Things to Know 

On March 28, 2024, CMS introduced a proposed rule aiming to modernize Medicare payment guidelines and rates for skilled nursing facilities (SNFs) operating under the Skilled Nursing Facility Prospective Payment System (SNF PPS) for the fiscal year 2025. The proposed adjustments include a 4.1% increase in SNF PPS rates, derived from a 2.8% market basket proposal, with a supplementary 1.7% market basket forecast error correction and a negative 0.4% productivity correction. It's worth noting that these proposed changes do not factor in reductions related to the SNF Value-Based Purchasing (VBP) program, which are estimated to amount to $196.5 million for FY 2025.

CMS aims to enhance the SNF Quality Reporting Program (QRP) by addressing adverse social conditions that can detrimentally affect individuals' health and healthcare. Furthermore, the proposed rule includes modifications to CMS' enforcement strategies, seeking to impose fairer and more consistent civil monetary penalties (CMPs) on SNFs for violations related to health and safety. CMS also suggests updating the SNF PPS wage index using Core-Based Statistical Areas (CBSAs) to ensure more accurate calculations of wages and associated costs based on the facility's location.

Top 5 Things to Know in the SNF FY 2025 Proposed Rule include:

1.    PDPM ICD-10 Code Mappings Update

CMS proposes revisions to the PDPM ICD-10 Code Mappings, aiming to enable providers to assign more precise and consistent primary diagnoses aligned with the criteria for skilled intervention during Medicare Part A SNF stays. 

Additionally, a Request for Information (RFI) is included to gather input on potential future updates to the Non-Therapy Ancillary (NTA) component of PDPM.

2.    Social Determinants of Health Changes (SDOH)

CMS suggests adding four (4) new SDOH items and modifying one (1) existing item starting from the FY 2027 SNF QRP. 

These include inquiries about:

           a.    Living Situation, 
           b.    Food (2 items), and 
           c.    Utilities. 

Additionally, adjustments are proposed to align the transportation item with the Accountable Health Communities HRSN Screening Tool. (Link to tool below.) 

                                     chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.cms.gov/priorities/innovation/media/document/ahcm-screeningtool-companion

3.    Civil Monetary Penalties (CMP)

The Proposed Rule outlines revisions to CMS' nursing home enforcement authority to enhance safety and care quality. 

These revisions aim to broaden the range and number of penalties in response to situations jeopardizing residents' health and safety. Changes allow for the imposition of more per instance and per day penalties, providing CMS with increased flexibility to address violations effectively.

Under the current system, penalties may be imposed under a:

       a.    Per Day (PD) or 
       b.    Per Instance (PI) 

basis depending upon the violation. 

Rules inhibit imposing both during the same survey, and PI penalties may not be imposed concurrently for multiple instances.

Changes to the rule allow the expansion of penalties to allow for more per instance and per day penalties to be imposed, providing CMS with greater flexibility to impose penalties in a manner that more directly reflects the health and safety impact to residents and incentivized correction.

4.    SNF Quality Reporting Program (QRP) Data Validation Process

Commencing with the FY 2027 SNF QRP, CMS suggests implementing an Audit Program for both MDS and Claims-Based items to ensure data accuracy and reliability.

5.    SNF Value Based Purchasing (VBP) Measures

CMS adopts two MDS-Based Quality Measures (QMs) in the SNF VBP effective from FY 2027 (October 1, 2026 – September 30, 2027) onwards.

        a.    These include the Percent of Residents Experiencing One or More Falls with Major Injury (Long-Stay) measure and the Discharge Function Score for SNFs (DC Function) measure. 

                    i.    Percent of Residents Experiencing One or More Falls with Major Injury (Long-Stay) (Falls With Major Injury (Long-Stay)) measure is currently reported on Care Compare and is used in the Five-Star Quality Ratings system.

                    ii.    Discharge Function Score for SNFs (DC Function) measure is the same Quality Measure that SNFs began collecting data for under the SNF QRP effective Oct. 1, 2023.

        b.    FY 2025 (October 1, 2024 – September 30, 2025) marks the initial performance period for both measures.

In summary, the proposed rule issued by CMS signals a critical opportunity for stakeholders to engage in dialogue and provide feedback to ensure that the final rule aligns with the best interests of both the industry and the broader public. It is imperative that individuals and organizations take advantage of the commenting period to offer insights and perspectives that will help shape policies that effectively meet the needs of patients, providers, and the healthcare system as a whole. By actively participating in this process, we can collectively work towards a final rule that promotes transparency, accountability, and quality improvement in skilled nursing facilities.

Sincerely,

Kris 

Kris B. Harmony OTR/L, LNHA, MBA

​President and CEO

KrisBHarmony, LLC

About Kris and KrisBHarmony, LLC

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