Skilled nursing leaders scrambled over the weekend to analyze a potentially exciting new patient classification system and proposed fiscal year 2019 payment rules that regulators unveiled Friday.
At least one association leader was happy to note that federal regulators had made significant changes to possibilities first floated last May in an Advanced Notice of Proposed Rule Making.
“It looks like [the Centers for Medicare & Medicaid Services] made several changes that will help patients and providers and are a great improvement over [the previously considered Resident Classification System-1],” said Cynthia Morton, executive vice president of the National Association for the Support of Long-Term Care, in an email to McKnight’s Sunday. The new model has 80% fewer possible payment group combinations.
“This will help the providers understand how their patients will classify into the various case-mix groups and reduce provider burden somewhat,” Morton noted.
At 266 pages, the skilled nursing payment rule was by far the longest of the four post-acute care payment rules CMS issued late Friday afternoon. Skilled nursing operators will see a 2.4% Medicare pay raise when fiscal 2019 starts Oct. 1 this year; the newly proposed Patient-Driven Payment Model (PDPM) would begin a year later.
CMS is collecting comments on its proposals until June 26. In addition, the agency will hold a special Open Door Forum conference call at 2 p.m. ET Tuesday to answer stakeholder questions.
Regulators projected that reduced reporting burdens would save providers $2 billion, primarily in labor costs, over 10 years.
“We see a couple big changes that NASL advocated for, including the ability to change a patient’s case mix group over the life of the stay,” Morton added on Sunday. “That particular aspect of RCS was static and the PDPM seems to recognize that the patient can and does change over the duration of their stay.
“I think most importantly for patients is that the PDPM records the amount of therapy provided to the patient — this was a significant omission in RCS,” she said. “We were gravely concerned — and our comments to CMS focused on this — that the structure of RCS allowed the possibility of stinting in care and or therapy for patients.”
Early analysis of the proposal shows that PDPM incorporates patient assessment information from Section GG instead of Section G. It’s a link to the IMPACT Act, Morton explained, noting that “CMS had been hit hard” by commenters complaining that 2017’s proposed RCS-1 had no intersects with requirements mandated by the IMPACT Act or other major laws.
“The big question is whether the application of the new model will result in assessing patients and then reimbursing for their care appropriately,” Morton said. “The answer to that question is something we will determine as we dig into the detail and better understand the model.”
Leaders at the country’s two largest nursing home associations said over the weekend that they were looking forward to analyzing the proposals more in depth.
“LeadingAge is pleased to see that the 2.4 percent market basket increase required by the Bipartisan Budget Act will increase SNF payments by $850 million, and that CMS heard our message loud and clear that the new classification system needed significant changes,” said Katie Smith Sloan, LeadingAge’s president and CEO, in a statement Saturday.
Smith Sloan said she is pleased that the proposals contain “extensive quality provisions” and changes to the Value-Based Purchasing and Quality Reporting programs. In addition, the proposed SNF and hospice payment rules both ask providers for ideas on how to achieve interoperability and the sharing of electronic health information.
The proposed Medicare pay “rate increase is critical,” added American Health Care Association President and CEO Mark Parkinson in early comments issued Friday evening.
“Adequate reimbursement and reasonable regulation must be a priority as skilled nursing prepares for the Gray Tsunami,” he said.