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CMS Finalizes 2019 SNF Payment Rule

The Centers for Medicare and Medicaid Services (CMS) released for public inspection the fiscal year (FY) 2019 skilled nursing facility (SNF) prospective payment system final rule on July 31, 2018.

A CMS fact sheet on the final rule, effective October 1, 2018, is also available highlighting the three main provisions of the rule, those being the new case-mix classification system, the Patient-Driven Payment Model (PDPM), and policy updates to the SNF quality reporting program (QRP) and value-based purchasing program (VBP). Of note, CMS states that the rule “moves Medicare towards a more value-based, unified post-acute care payment system” which signals that this is likely foundational to the future concept of a unified post-acute care prospective payment system as mentioned in the IMPACT Act of 2014.

SNFs will receive a 2.4% payment update for FY 2019 based on the Bipartisan Budget Act of 2018. CMS took the recommendation of LeadingAge that organizations that failed to meet the QRP requirements have an update of 0.4% as opposed to -0.1% in the proposed rule with the 2% reduction for reporting noncompliance.

The PDPM proposal retains the implementation date of October 1, 2019. LeadingAge provided comments on the PDPM and other aspects of the proposed rule based on our analyses and input received from our members. CMS has indicated that information on training and education resources and opportunities associated with implementing the PDPM will be available on the CMS website. LeadingAge has joined other stakeholder groups in asking CMS for a PDPM stakeholder workgroup to proactively address transition and implementation challenge issues as well as aiding with education and dissemination of CMS guidance.

The Patient Driven Payment Model (PDPM) is a significant change for how Medicare is paying for skilled nursing. The focus on beneficiary clinical characteristics appears to be the clear direction of the future as CMS considers other payment systems, home health as an example, and post-acute care as a Medicare segment. LeadingAge will strive to ensure our members are positioned to transition successfully and in an educated manner.

LeadingAge is analyzing the final rule and will provide additional information through multiple communication channels.

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Our national partner, LeadingAge, is an association of 6,000 not-for-profit organizations dedicated to expanding the world of possibilities for aging. Together, we advance policies, promote practices and conduct research that support, enable and empower people to live fully as they age.