SNF FY 2021 Proposed Rule Summary

On April 10, CMS released the FY 2021 SNF Proposed Rule. Although there are no major changes, there are many items of interest. For example, the Wage Index changes reimbursement for many. Read more.
April 16, 2020
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1.      Cost and Benefits

  • SNF PPS Payment Rate Update: $784 Million
  • SNF VBP Changes: - $199.54 million

2.      Market Basket Percentage:

  • 2.3% (2.7% - 0.4% [multifactor productivity adjustment] = 2.3%)

3.      PDPM Case-Mix Unadjusted Federal Rates

4.      Wage Index

Propose to adopt revised OMB delineations for wage data based on Metropolitan and Micropolitan Statistical Areas

  • Micropolitan Area: associated with at least one urban cluster with a population of at least 10,000 but less than 50,000 –“rural”
  • 34 urban counties would become rural
  • 47 rural counties would become urban (i.e.,Ottawa County, Toledo, OH; Jackson County, Charleston, WV; Morgan County, Hagerstown-Martinsburg, MD-WV)
  • 31 urban counties would have a change in Name or Number of CBSA (25540 Hartford-West Hartford- East Hartford, CT to 25540 Hartford-East Hartford-Middletown, CT; 19380 Dayton, OH to 19430 Dayton-Kettering, OH)
  • 19 urban counties would move from one urban CBSA to another (i.e., Lincoln, WV 26580 – Huntington-Ashland-WV-KY-OH to 16620 Charleston, WV) 

Note: CBSA – Core Based Statistical Areas

42% of SNFs would experience a decrease in their area wage index values

  • 2% would experience a significant decrease in their area wage index value (> 5%)

54% of SNFs would have a higher area wage index

  • 1-year transition - will apply a 5% cap in FY 2021 on any decrease in a wage index compared to FY 2020; no cap 2nd year
  • Budget neutrality factor – 0.9982
  • OMB issued another update/bulletin on March 6,2020 (bulletin 20-01), which will be used to for FY 2022 SNF PPS proposed rule

5.      Regulation Text

  • Revise/update example related to “practical matter” criterion noting “we would revise the regulation text on this point to provide as an example that the unavailability of Medicare payment foroutpatient therapy due to the beneficiary’s enrollment in Part B cannot serve as a basis for finding that the needed care can only be provided on an in patient basis in SNF”.
  • Revise § 413.114(c)(2) to remove an erroneous cross-reference to a non-existent § 413.55(a)(1) and indicate correct cross reference of § 413.53(a)(1)

6.      PDPM ICD-10 Mappings Changes

7.       SNF Value Based Purchasing (VBP)

  • Intend to submit measure – Skilled Nursing Facility 30-Day Potentially Preventable Readmission Measure (SNFPPR) – to NQF (National Quality Forum) during the Fall 2021 cycle and once this is complete,transition timing will be assessed
  • Changed name of measure to Skilled Nursing Facility Potentially Preventable Readmissions after Hospital Discharge in FY 2020 to differentiate between this measure and the similar measure in the SNF QRP
  • Question: How will the FY 2022 (performance period FY 2020) and FY 2024 (baseline period FY 2020) be impacted?
  • No updates to the measure, scoring, or payment policies related to SNF VBP at this time

8.      Nursing Home Compare Website or Successor Website

  • Propose to codify data suppression policy for low-volume SNFs
  • Propose to amend regulation to reflect public reporting of SNF performance information on the Nursing Home Compare Website or a successor website
  • CMS announced a website transition on a public internet blog on January 2020
  • Will update SNFs and other stakeholders through internet and other widely used communication modes closer to transition date

Propose to apply 30-day Phase One Review and Correction deadline to the baseline period quality measure report typically issued in December (would align with performance period quality measure quarterlyreport issued in June)

  • SNFs would have 30 days following issuance of those reports to review and then to submit a correction request
  • If issuance dates are significantly delayed, CMS would notify SNFs through routine communication channels

9.   Invite comments on:

  • Impact of PDPM Implementation on providers and patient care
  • HCPCS codes in 4 service categories(chemotherapy items, chemotherapy administration services, radioisotope services, and customized prosthetic device), which may meet the criteria forexemption from consolidated billing based on recent medical advances
  • Amending the regulation text to reflect the updated measure name for SNF VBP
  • Proposal to codify performance standards correction policy for SNF VBP as finalized in FY 2019  

Note: This proposed rule and all rate and wage indexes of the rule applies to all non-CAH swing-bed rural hospitals as well as SNFs.