I remember when the Patient Driven Payment Model rule was just a proposal inching its way toward finalization, its concept of assigning points for specific non-therapy ancillary costs a pretty exciting way of rethinking how providers would get paid for care they might already be delivering.
Sure, there were some early questions about whether providers might somehow milk the system or maybe aim to draw in patients they couldn’t adequately care for. But those concerns, at least to my outsider’s eye, have largely been non-starters over the last few years.
Think about how nursing home care has changed since 2018, when the rule was finalized, or 2020, when an acute-care crisis called COVID-19 turned some of America’s nursing homes into advanced respiratory care centers for the very, very ill.
Nursing homes have continually risen to the occasion over the last five years, finding both that hospitals need post-acute partners who can take more complex patients (and more of them than ever before) and that Medicare payments for those complex services (IVs, parenteral IV feeding, treatments for COPD and lots more) are often a strategic route to a SNF operator’s survival.
So it makes sense now that the Centers for Medicare & Medicaid Services is reassessing its NTA component, to see whether some services might be less deserving of those extra points — and if there are some services that were only just beginning to be delivered in the nursing home setting less than a decade ago.
This NTA business proposed in the 2025 skilled nursing pay rule? Take it as a compliment.
CMS SNF Team Lead John Kane last year warned that the agency wanted to make some changes. It finally has years of data in hand, and enough of it has been collected outside the pandemic to see patterns in non-COVID care.
He said the system would need to “evolve” to represent an accurate portrayal of SNF care. Now, here is an opportunity for providers who want to expand their capabilities and can envision the new service lines coming into play to color the payment model.
“We have updated the payment rates but not much of the underlying payment model since we implemented PDPM,” Kane said on Tuesday’s SNF Open Door Forum call. “Based on our own analysis and some of the things that we have talked about in the rulemaking in past years, as well as stakeholder feedback that we have received over the years, we felt it was appropriate to consider ways that we might update PDPM based on changes in patient population, changes in care provision.”
Basically, CMS is taking a well-informed guess as to what’s increasingly prevalant in nursing homes today and what’s coming next when it comes to clinical capabilities.
My colleague Jim Berklan earlier this week brought you commentary from experts on items that could get added to the NTA list, including chemo or autoimmune drugs or certain scans that aren’t included in lump-sum payments.
Those could be fresh opportunities for providers to capitalize on the continuing modernization of nursing home care.
Comments on the proposed rule, including a request for information on the NTAs, are due by late May. Changes would tentatively kick in in late 2026. Only you can see what your teams are truly capable of doing in the skilled nursing setting now and 18 months from now; make sure that CMS gets the picture too.
