The Society Submits Comments on CMS SNF PPS Proposed Rule

AMDA-The Society for Post-Acute and Long-Term Care Medicine recently submitted comments on the Centers for Medicare & Medicaid Services (CMS) proposed rule entitled Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities FY 2017, SNF Value-Based Purchasing Program, SNF Quality Reporting Program, and SNF Payment Models Research; Proposed Rule.

The Society noted that, “members often follow patients across the Post-Acute Care (PAC) spectrum, and as CMS tries to standardize measures across all PAC settings (IMPACT Act), clinicians could be a vital component in achieving standardization and improving quality.” The Society further urged CMS to harmonize measures across clinician and facility quality reporting programs stating “As MACRA defines physician quality measures and Alternative Payment Models, we recommend to CMS that clinician measures and PAC facility measures be harmonized.”

CMS has proposed a measure to report a skilled nursing facility’s (SNF’s) risk-standardized rate of Medicare Fee For Service (FFS) patients who are discharged to the community following an SNF stay and who remain alive and do not have an unplanned readmission to an acute care hospital or long-term care hospital (LTCH) in the 31 days following discharge to the community. Community for purposes of this measure is defined as home/self-care, with or without home health services. CMS notes that this measure is conceptualized uniformly across the PAC settings, and sets out its extensive analyses of the data on variation in discharge patterns and costs.

The Society noted that those residents of the facility prior to the SNF stay should be excluded from the numerator and denominator, as they are not expected to return to the “community” because they reside in the facility (on NF or custodial status) and the facility is and will remain their home. “These individuals were hospitalized for an acute problem; while they may return as skilled (SNF – place of service 31) residents receiving skilled services for a short period, they ultimately will resume custodial (NF – place of service 32) status in the facility. The facility should not be penalized in such situations,” the Society’s letter stated.

CMS also proposed a Medicare Spending Per Beneficiary (MSPB) PAC SNF measure to hold SNF providers accountable for Medicare payments within an episode of care. The Society strongly supports the inclusion of socioeconomic and demographic factors in the MSPB-PAC measure before adoption. “It will allow for more fair and equitable determination of true costs among providers, will help prevent “cherry-picking,” and the granularity will assist in meaningful improvement in populations who historically have differing needs and costs,” the Society said. The Society also urged CMS to adjust for socioeconomic and demographic factors before the measure is finalized. “Failure to account for very real differences in underlying patient health status and support systems that would permit more timely discharge to community results in the demonstrated poor predictive power of the MSPB-PAC resource use measure as applied to SNF patients.” In addition, the Society noted the importance of ensuring “that the risk adjustment methodology compares similar populations. For instance, spending on the skilled post-acute patient, defined by place of service 31, would be very different from a non-skilled resident defined by place of service 32. We strongly urge CMS to use claims data to further adjust these populations based on these differences.”

To read the entire letter click here.