On July 29th, CMS issued the Final SNF PPS Rule for FY 2023 effective 10/1/2022. Advocacy was absolutely key in the changes that were recognized in the final vs. the proposed rule which resulted in a surprising 2.7% increase as compared to FY 2022. This increase is the result of a 5.1% update to the payment rates (3.9% market basket increase plus a 1.5% market basket forecast error adjustment, less a 0.3% reduction for multifactor productivity adjustment) minus the parity adjustment, which is now being split equally at 2.3% over 2023 and 2024 vs. the proposed 4.6% reduction hitting at once.
Additional items of note in the final rule:
- Permanent 5% cap on the annual wage index – decreases to ‘smooth year-to-year changes’ in payments is being finalized by CMS.
- ICD-10 code mapping – updates are being finalized.
- New SNF QRP process measure – Influenza vaccination coverage among Healthcare Personnel (HCP) measure for the SNF QRP will begin with FY 2024. SNFs will begin submitting the measure data through the CDC National Health Care Safety Network with an initial data submission period from Oct. 1, 2022 – March 31, 2023.
- QRP Transfer Health Information – measure compliance date pushed to at least October 1st of the year that is at least two full fiscal years after the end of the COVID-19 PHE.
- VBP SNF 30-Day All-Cause Readmission Measure (SNFRM) – will not be applied as part of the performance scoring for the FY2023 VBP Program Year. CMS will assign a performance score of 0 to all participating SNFs, irrespective of how they perform. CMS will reduce the per diem rate for each SNF by 2% and award 60% of that withhold, resulting in a 1.2% payback to SNFs. SNFs that do not meet the case minimum for FY 2023 will be excluded.
- SNF VBP Program Expansion – two claims-based and one payroll-based journal staffing measure.
- FY 2026 Adoption of the:
- Skilled Nursing Facility Healthcare Associated Infections requiring hospitalization (SNF HAI)
- Total Nursing Hours per Resident Day measures
- FY 2027 Adoption of:
- Discharge to Community – Post-Acute Care Measure for SNFs (DTC)
There’s much more to be found in the CMS Fact Sheet (see attached) distributed on July 29, 2022.
Let’s Get to the Point:
While there is much to digest in the FY 2023 SNF Final Rule, recognizing that advocacy efforts were heard and adjustments were made to ease the financial burden slightly is of great significance.
