LeadingAge weighs in on proposed payment rule
The comment period for the Medicare proposed rule for SNFs just ended. Here's what LeadingAge had to say in comments submitted:
Wage Index Adjustment
As CMS continues to utilize the hospital wage index in developing the SNF wage index, and changes have been proposed in the Hospital Inpatient Prospective Payment System (IPPS) proposed rule to address wage index disparities between high- and low-wage index hospitals, LeadingAge requests clarification on how those changes would impact the SNF wage index and recommends CMS examine wage index disparities to identify any issues to address relative to SNFs.
Changes Related to the Patient-Driven Payment Model (PDPM)
LeadingAge supports PDPM-related changes such as updating the regulatory text to more accurately reflect terms that will be utilized with the implementation of PDPM and supports the revision of the group therapy definition to reflect services provided to groups of 2 to 6 individuals. CMS proposed a subregulatory process to make non-substantive changes to ICD-10 code mappings and related software and while we support this change, we request clarification on when providers can expect these updates to take place in order to reduce the administrative burden and margin for error associated with unpredictable updates.
Several changes were proposed for quality measures in both the SNF Quality Reporting Program (QRP) and the SNF Value-Based Payment (VBP) program. We suggest further exploration or development of several of the measures proposed for FY 2022 QRP to ensure that any adopted measures present an accurate picture of care, such as adding qualifiers to questions assessing social determinants of health and conducting a further review of instruments measuring mood status. LeadingAge supports the exclusion of baseline nursing home residents from the QRP discharge to community measure and the name change proposed for the VBP measure related to hospital readmission.