CMS issued the FY2021 SNF PPS Proposed Rule (effective October 1, 2020) on 4/10/20 with a 2.3% payment increase yielding an approximate increase of $784 million in payments to SNFS. Other changes to the code mappings for PDPM case-mix classification and updates for the SNF Value-Based Purchasing (VBP) Program were also proposed. The comment period is open until June 9th. Access the Fact Sheet at:: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-2021-proposed-medicare-payment-and-policy-changes-skilled-nursing-facilities-cms-1737-p. The Proposed Rule is published in the 4/15/20 Federal Register.
Other updates included in the FY2021 SNF PPS Proposed Rule include:
Base Rate Updates for PDPM Components for FY2021 including the proposal that the unadjusted federal rate per diem for urban and rural will be updated as follows, prior to adjustment for case-mix:
Table 3: FY 2021 Unadjusted Federal Rate Per Diem – URBAN
| Rate Component | PT | OT | SLP | Nursing | NTA | Non-Case-Mix |
| Per Diem Amount | $62.04 | $57.75 | $23.16 | $108.16 | $81.60 | $96.85 |
Table 4: FY 2021 Unadjusted Federal Rate Per Diem – RURAL
| Rate Component | PT | OT | SLP | Nursing | NTA | Non-Case-Mix |
| Per Diem Amount | $70.72 | $64.95 | $29.17 | $103.34 | $77.96 | $98.63 |
Changes in SNF PPS Wage Index proposed based on the revised Office of Management and Budget (OMB) delineations as described in the September 14, 2018, OMB Bulletin No. 18-04, for the SNF PPS wage index effective beginning in FY 2021. CMS is also proposing to implement a 1-year transition policy under which it would apply a 5 percent cap in FY 2021 on any decrease in a hospital’s wage index compared to its wage index for the prior fiscal year (FY 2020) to assist providers in adapting to the revised OMB delineations.
PDPM monitoring continues including assessment of the overall impact of PDPM budget neutrality and specifically that CMS continues “to monitor the impact of PDPM implementation on patient outcomes and program outlays, though we believe it would be premature to release any information related to these issues based on the amount of data currently available.”
PDPM ICD-10 coding updates were proposed to the ICD-10 code mappings for PDPM case-mix groups including, two surgical clinical category options which may be eligible for the Non-Orthopedic Surgery Category, or which may be eligible for one of the two Orthopedic Surgery Categories. The proposed updated mappings and lists will be posted at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/PDPM.
Proposed Aligning SNF Value-Based Purchasing (VBP) Program regulations found at 42 CFR § 413.338 with previously finalized policies, and the amendment of the definition of “performance standards” at § 413.338(a)(9), consistent with the policies finalized in the FY 2019 SNF PPS final rule, to reflect CMS’s ability to update the numerical values of performance standards if CMS determines there is an error that affects the achievement threshold or benchmark. CMS also proposed measures to align the Phase One Review and Correction deadlines for the quarterly reports that contain the underlying claims and measure rate information for the baseline period or performance period. This would allow SNFs 30 days following report issuance to review underlying claims and measure rate information. Correction requests could be submitted within 30 days following issuance of the reports. CMS is also proposing to establish performance periods and performance standards for upcoming program years, and is proposing to amend section 13.338(e)(3) to reflect that the agency will publicly report SNF performance information on the Nursing Home Compare website or a successor website.
Health IT and advancement of provider interoperability was addressed including the establishment of a Post Acute Care Interoperability Workgroup.
Blog by Amie Martin, OTR/L, CHC, RAC-CT, Proactive Medical Review
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