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In a recent announcement, the Centers for Medicare & Medicaid Services (CMS) unveiled a series of pivotal Medicare payment system updates to Medicare payment policies for Skilled Nursing Facilities (SNFs) for the fiscal year 2024. These changes are designed to improve care and streamline administrative processes. 

The changes can be summarized as follows

1. A Boost in Payment Rates

SNFs can anticipate a net increase of 4.0%, or an approximate surge of $1.4 billion, in Medicare Part A payments. This is attributed to a $2.2 billion hike stemming from the 6.4% net market basket update. Of course, this boost will be slightly offset by a decrement associated with the second phase of the Patient-Driven Payment Model (PDPM) parity adjustment recalibration.

2. Refinements in PDPM and ICD-10 Code Mappings

The CMS has diligently updated the diagnosis code mappings utilized under PDPM, a pivotal component in the Medicare payment structure. In a bid to maintain alignment with the evolving medical landscape, several changes have been finalized in the PDPM ICD-10 code mappings, ensuring they resonate with the current ICD-10 coding guidelines.

3. Quality Reporting Sees Revamp

As part of the Medicare payment system updates, the CMS is integrating two new measures into the SNF Quality Reporting Program (QRP), phasing out three existing ones, and introducing modifications to another. These changes are not superficial but rather come with underlying policy shifts in the SNF QRP. Stakeholders can also expect the commencement of public reporting for four distinct measures, marking a move towards increased transparency in the sector.

4. Value-Based Purchasing Program Undergoes Refinement

The SNF Value-Based Purchasing (VBP) Program, designed to incentivize facilities based on the quality of care they deliver, is witnessing a series of updates. CMS is onboarding four new quality measures, phasing out one, and rolling out a slew of policy changes. 

Here’s a quick rundown: 

A group of nurses who are done learning about the Medicare payment system updates.
Starting from the FY 2026 program year, the CMS is introducing the Nursing Staff Turnover Measure.
  • Emphasis on Staffing Stability: Starting from the FY 2026 program year, the CMS is introducing the Nursing Staff Turnover Measure. This measure not only assesses the stability of staffing within Skilled Nursing Facilities (SNFs) but also underscores the broader initiative to ensure adequate staffing in long-term care settings. This move aligns with the President’s Executive Order 14070, which emphasizes high-quality care and support for caregivers. Facilities should take note that reporting for this measure kicks off in FY 2024, with payment implications set for FY 2026.
  • Focus on Functional Status: The Discharge Function Score Measure, set to begin in FY 2027, aims to evaluate the functional status of SNF residents. By leveraging mobility and self-care data from the Minimum Data Set (MDS), this measure will provide insights into the percentage of residents meeting or exceeding expected discharge function scores.
  • Monitor Long-Stay Residents: Two new Medicare payment system updates, starting in FY 2027, will provide a closer look at the well-being of long-stay residents. The Long Stay Hospitalization Measure will assess the hospitalization rate, while the Percent of Residents Experiencing One or More Falls with Major Injury will shed light on safety concerns related to falls.
  • A Shift in Readmission Metrics: In a significant move, the CMS will replace the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) with the Skilled Nursing Facility Within Stay Potentially Preventable Readmissions (SNF WS PPR) measure come FY 2028.

5. A Nod to Mental Health Professionals

In a move that underscores the importance of mental health in comprehensive patient care, services rendered by marriage and family therapists (MFT) and mental health counselors (MHC) will be excluded from SNF consolidated billing. This change empowers these professionals to bill their services independently, ensuring they receive due recognition and compensation for their specialized services.

6. Streamline Civil Money Penalties

The CMS, through the Medicare payment system updates, has revamped its approach to Civil Money Penalties (CMP) in an effort to address administrative bottlenecks. The agency has adopted a constructive waiver process, simplifying the procedure for facilities. If the CMS doesn’t receive a hearing request within the designated timeframe, facilities are automatically deemed to have waived their hearing rights and the accompanying 35% penalty reduction would remain unchanged.

7. Prioritize Staff and Care Quality

Echoing the sentiments of the president’s Executive Order 14070, the final rule has incorporated a measure specifically targeting staff turnover. This move is in line with the broader objective of bolstering access to high-caliber care and offering unwavering support to caregivers.

8. Simplifying Waiver Requirements

In another administrative simplification, the mandate for facilities to formally waive their right to a hearing in writing has been rescinded. A constructive waiver approach will be employed if a facility refrains from submitting a hearing request.

For those marking their calendars, the new regulations are set to be effective from October 1, 2023. However, it’s crucial to note that certain amendments will only come into play from January 1, 2024. Experience Care will keep readers updated on any new developments.

Elijah Oling Wanga