The Society Urges CMS to Delay Parity Payment Adjustment for SNFs

The Society recently submitted comments on the Centers for Medicare & Medicaid Services (CMS) proposed rule for the Fiscal Year 2023 Skilled Nursing Facility Prospective Payment System (PPS). The proposed rule called for an approximately $320 million decrease in Medicare Part A payments for skilled nursing facilities (SNFs). This estimate reflects a $1.4 billion increase from the 3.9% update to the payment rates, which is based on a 2.8% SNF market basket update plus a 1.5 percentage point market basket forecast error adjustment, less a 0.4 % point productivity adjustment as well as a negative 4.6% or $1.7 billion decrease in the SNF PPS rates as a result of the proposed recalibrated parity adjustment.

The Society recommended a delayed or phased-in approach to the parity adjustment amount rather than a one-time adjustment. “CMS should lock in the parity adjustment amount this year after considering public comments regarding the appropriate percentage methodology, and then phase in the reduction evenly over three years (e.g. 1.5 percent per year).”

The Society also made a number of recommendations on the CMS request for information on revising the staffing requirements for long-term care facilities. The Society urged CMS to not take a one-size-fits-all approach to staffing as it is a very nuanced and complex issue. The Society noted that while having enough staff is critical, staffing levels based only on resident-to-worker ratios or assumptions that staff availability is an easy fixable variable, will not adequately or safely address and meet resident needs.

The Society also supported the use of an SNF QRP influenza vaccination coverage among health-care personnel measure, but noted that the data collection of the measure must be very clear and not add undue burden on facilities, especially with the threat of a 2% penalty for not complying with the measure.

Read the entire comment letter.