Major Changes to SNF VBP Program: What You Need to Know to be Successful

Major Changes to SNF VBP Program: What You Need to Know to be Successful

The Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program continues to evolve, with CMS expanding the scope of this quality incentive program beyond the hospital readmission measure to include additional measures reflective of both clinical outcomes and operational performance. These measures aim to align financial incentives with high-quality resident-centered care. Let’s break down what’s changed, what’s coming, and how you can prepare.

Shift from a Single Measure to a Multi-Measure Framework

Historically, the SNF VBP program solely focused on rewarding facilities based on their ability to reduce unplanned hospital readmissions. The key metric was the SNF 30-Day All-Cause Readmission Measure (SNFRM), which was calculated using Medicare Part A claims from both SNFs and hospitals. It excluded MDS data and focused on patients readmitted within 30 days of hospital discharge.

New Measures for FY2026

Baseline Period: FY 2022 Performance Period: FY 2024

CMS has expanded the SNF VBP program to include three new measures for a total of 4 SNF VBP measures during this period and will also add one measure effective with FY 2027, signaling a shift toward a more holistic view of SNF performance.

FY2026 Measures:

1. Healthcare-Acquired Infections (HAI) Requiring Hospitalization

• • Based on SNF and hospital claims data with no additional submission requirement
  • Tracks preventable infections acquired in the SNF that result in hospital admission
  • Promotes strengthened infection control protocols in the SNF

2. Total Nursing Hours per Resident Day

• • Measures the average daily hours of nursing staff per resident
  • Derived from Payroll-Based Journal (PBJ) and MDS data
  • Currently used in the 5-Star Quality Rating System
  • Highlights adequacy of staffing and resident acuity

3. Nursing Staff Turnover

• • Assesses the rate of staff departures over a defined period
  • Derived from Payroll-Based Journal (PBJ) data
  • Also used in the 5-Star Quality Rating System
  • Highlights impact of nursing staff turnover rates on quality resident care

FY2027 Measure:

4. Discharge to the Community

• • Currently used in the SNF Quality Reporting Program (QRP).
  • Based on two years of fee-for-service claims.
  • Evaluates successful discharge to the community without readmission or death

Baseline Period: FY 2021 – 2022 Performance Period: FY 2024 – FY2025

Scoring Methodology Overhaul

With the addition of the new measures, CMS is revamping the scoring methodology, which had been built around a single metric to accommodate multiple domains. This new approach to scoring encourages both top level performance and year-to-year improved progress.

Scoring Components

• • Achievement Score (0-10 points): Compares the SNF performance during the performance period to the national SNF performance during the baseline period
  • Improvement Score (0-9 points): Compares SNF’s performance to their own baseline
  • Final Measure Score: The higher of the two scores for each measure is used as that measure’s final score
  • Normalization: Each measure is then rescaled to ensure comparability across measures
  • Total Performance Score: Normalized scores are added together to determine the total performance score ranging from 0-100 points

SNFs achieving a higher TPS are considered to be performing better than their peers under VBP and will have a positive payment impact under this program.

Know your SNF’s Data:

SNF providers can access their confidential performance data through the iQIES CASPER reporting system, which includes:

• • Baseline reports
  • Interim Reports
  • Performance score reports
  • Incentive Payment Multiplier (IMP) reports

CMS offers a two-phase review and correction process:

• • Phase 1: Measure Results Review
    • Scope: Review and correct errors in the calculation of the measure results for the baseline and performance data
    • Limitations: Corrections are only allowed for errors made by CMS or its contractors.
    • SNFs cannot correct the data for the following:
      • Claims
      • Payroll-based journal (PBJ)
      • Minimum Data Set (MDS)
  • Phase 2: Performance Scores and Ranking Review
    • Scope: Review and Correct error in performance scores and rankings
    • Limitations: As above, only CMS or contractor calculations errors can be corrected.

Action Steps:

• • Know your data! FY 2026 IMP reports are available for review and CMS will issue the baseline data for all measures impacting FY2027 in December. It is important to review and be familiar with this data
  • Continue to focus on reducing hospital readmissions
  • Review baseline and performance data for each of the measures.
  • Monitor staffing levels and validate accurate and timely PBJ reporting.
  • Track discharge outcomes and community reintegration success.
  • Use CASPER reports to identify trends and opportunities for improvement.

The SNF VBP program is evolving—and SNFs must also evolve under this new VBP methodology. With new measures in place and an increased focus on quality, SNFs have an opportunity to redefine excellence in post-acute care. Proactive engagement with CASPER reports, strategic planning, and a commitment to continuous improvement will be key to achieving financial success under the expanded VBP framework for incentive payments.

Next Steps:

Contact Proactive for VBP focused training, systems improvement and QA monitoring of performance data.

Written By:

Christine Twombly, RN-BC, RAC-MT, RAC-MTA, HCRM, CHC

Senior Consultant

Proactive LTC Consulting