The SNF VBP program encourages SNFs to improve the quality of care provided to Medicare beneficiaries by awarding incentive payments to SNFs based on their performance in the area of reducing unplanned hospital readmissions. Currently, the SNF VBP program utilizes the SNF 30-day All-Cause Readmission Measure (SNFRM) to evaluate the risk standardized readmission rate of all unplanned, all cause readmissions.
The SNF 30-day All-Cause Readmission Measure (SNFRM) is calculated using data from both SNF and hospital Medicare Part A claims submitted for payment during each period. Information from MDS is not used with this Measure. The measure includes Medicare Part A Beneficiaries who are admitted to the SNF directly from the hospital and have an unplanned readmission to the hospital within 30 days of the prior hospital discharge. The measure is risk-adjusted based on patient demographics, comorbidities, and other factors that influence the probability of readmission, including a COVID-19 diagnosis. The results for this measure are calculated for each SNF for both a baseline and performance period.
For the FY2023 program year, the baseline period is calculated from data from FY 2019 (10/1/2018 -9/30/2019) and the performance period uses data from FY2021 (10/1/2020 -9/30/2021).
SNFs’ risk-standardized readmission rate (RSRRs) in the performance period are compared to two metrics to determine the performance score:
- The SNF’s own past performance during the baseline period used to calculate an improvement score (with scores ranging from 0 to 90)
- National SNF performance during the baseline period, used to calculate an achievement score (scores range from 0 to 100)
CMS compares a SNF’s achievement and improvement scores; whichever score is higher is the SNF’s performance score.
Impact on payment during FY2023
CMS withholds 2% of each SNF’s Medicare Part A payment to fund the VBP program. 60% of the amount withheld is then redistributed to SNFs as an incentive payment, with the remaining 40% retained in the Medicare Trust Fund. Due to the continuing effects of the COVID-19 Public Health Emergency (PHE), for the purpose of performance score and payment adjustments during FY2023 CMS suppressed the measure and assigned each SNF with a performance score of 0. Under this suppression policy, each SNF received an incentive payment multiplier of equal to 60% resulting in a 1.2% payback during the current fiscal year.
Know your SNF’s Data
CMS provides confidential feedback reports to each SNF provider through the CASPER reporting system. The follow data is available to review:
- Quarterly reports for each of the 4 quarters during the calendar year
- Interim (partial year) workbook
- Full year baseline period and full year performance period workbook
- Performance score report
There is a review and correction process that has two phases and allows for correction requests to be accepted up to 30 days after the report is issued.
- Phase 1: applies to the full year workbook only and allows for corrections to be submitted to readmission measure rates for the baseline and performance period
- Phase 2: applies to the Performance Score reports only and allows for corrections to the performance score.
In the FY2023 SNF PPS Final Rule, CMS finalized three new measures that will be added to VBP in FY 2026 and 2027.
The following two new measures will be effective for FY 2026:
- Healthcare-Acquired Infections (HAI) Requiring Hospitalization – The HAI measure is based on SNF and hospital claims and does not require additional data reporting.
- Total Nursing Hours per Resident Day. The staffing measure is the same as already used for the 5-Star Quality Rating System, taken from Payroll Based Journal and MDS data.
- For both measures, CMS will use FY 2024 as the performance period and FY 2022 as the baseline period for the FY 2026 program year, then roll forward.
For FY 2027, CMS adopted the following measure:
- Discharge to Community measure. This measure is already in use for SNF QRP. It is based on 2 years of fee-for-service claims.
- Baseline period for this measure will be FY 2021-2022, and the performance period will be FY 2024-2025.
The implementation of these new measures will require CMS to change other aspects of VBP that are based on the current single-measure structure, including the scoring methodology.
SNF providers have access to data and their performance with these additional measures through CASPER and should be begin reviewing baseline data for the HAI measure with a focus on improvement in this measure during the performance period.
Interested in learning more? Join us on March 21, 2023 for the webinar ABCs of QRP and VBP for an in depth discussion of these important facility outcome measures and best practices to improve your facility’s performance.
Written By: Christine Twombly, RN-BC, RAC-MT, RAC-MTA, HCRM, CHC
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