The future of quality-driven care is coming. Is your therapy team ready?

Reviews of the FY 2022 SNF PPS Proposed Rule often highlight key areas related to data trending, lack of budget neutrality and forthcoming options for parity adjustments.

While we all need to understand these key elements and prepare for associated change, it is equally essential for therapy providers and teams to understand trends and proposals around quality.


Remember the aim of the IMPACT Act?

The Improving Medicare Post-Acute Care Transformation Act (IMPACT) Act of 2014 requires the Secretary to implement specified clinical assessment domains using standardized or uniform data elements to be nested within the assessment instruments currently required for submission by long-term care hospital, inpatient rehabilitation facility, skilled nursing facility and home health agency providers.

As such, the proposed rule for FY 2022 includes significant updates to the SNF Quality Reporting Program.

Let’s begin with a historical refresher.

There are currently 11 quality measures: eight from the minimum data set and three from Medicare claims.

Claims Based

  • Medicare Spending Per Beneficiary – Post-Acute Care
  • Discharge to Community (5-star)
  • Potentially Preventable 30-Day Post-Discharge Readmission Measure

MDS Based

  • Application of Percent of Residents Experiencing One or More Falls with Major Injury
  • Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function
  • Drug Regimen Review Conducted with Follow-Up for Identified Issue
  • Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury (5-Star)
  • SNF Functional Outcome Measure: Change in Self-Care Score for Skilled Nursing Facility Residents
  • SNF Functional Outcome Measure: Change in Mobility Score for Skilled Nursing Facility Residents
  • SNF Functional Outcome Measure: Discharge Self-Care Score for Skilled Nursing Facility Residents
  • SNF Functional Outcome Measure: Discharge Mobility Score for Skilled Nursing Facility Residents

FY 2021

Proposed and final rules identified the addition of two MDS measures (MDS 3.0 v1.18.0 post pandemic implementation) and Standardized Patient Assessment Data Elements (SPADES).

Included areas are below.

  • Transfer of Health Information to the Provider–Post-Acute Care (PAC);
  • Transfer of Health Information to the Patient–Post-Acute Care (PAC).
  • 3 SPADEs for Cognitive Function.
  • 15 SPADEs to Assess for Special Services, Treatments, and Interventions.
  • 1 SPADE to Assess for Medical Conditions and Comorbidities.
  • 2 SPADEs to Assess for Impairments
  • 5 SPADEs to assess for a new category: Social Determinants of Health.

FY 2022

Proposed rule adds two more measures to the SF QRP which are proposed to be implemented starting October 2021.

  • Claims Based: Skilled Nursing Facility (SNF) Healthcare-Associated Infections (HAIs) Requiring Hospitalizations Measure for the Skilled Nursing Facility Quality Reporting Program.
  • NHSN Reporting: COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure

Interestingly, the FY 2022 Proposed Rule also included frailty, patient-reported outcomes, shared decision-making process, appropriate pain assessment and pain management processes, and health equity in its measures under consideration for the future.

Therapists should familiarize themselves and care teams with the metrics noted above as there are clear synergies with rehab provision in areas associated with evidence-based practice for frailty; need to create plans of care and goals which will allow for effective person centered outcomes and shared decision making placing the patient at the center of care; thorough assessment and treatment of pain; and obvious recognition of health equity which the pandemic has caused us all to appreciate.

The shift to quality is coming. Is your therapy team prepared? The future will soon tell.

Renee Kinder, MS, CCC-SLP, RAC-CT, is Executive Vice President of Clinical Services for Broad River Rehab and a 2019 APEX Award of Excellence winner in the Writing–Regular Departments & Columns category. Additionally, she serves as Gerontology Professional Development Manager for the American Speech Language Hearing Association’s (ASHA) gerontology special interest group, is a member of the University of Kentucky College of Medicine community faculty and is an advisor to the American Medical Association’s Relative Value Update Committee (RUC) Health Care Professionals Advisory Committee (HCPAC).