Q: Can you find any positives for nursing homes in the 2023 proposed prospective payment rule?
A: Certainly, the Centers for Medicare & Medicaid Services landed a fiscal gut punch to nursing homes with its Skilled Nursing Facility Prospective Payment System proposed rule for FY 2023. While CMS is legally obligated to update Medicare payment policies for nursing homes on an annual basis, this proposed rule left SNFs gasping for air.
A 4.6%, or $1.7 billion, downward adjustment meant to offset overpayments during the transition to the Patient Driven Payment Model will result in a takeaway of about $320 million in Medicare Part A payments to SNFs. What is particularly hard to understand is how the Biden Administration could believe that such cuts will not harm the president’s goals of increased staffing and quality improvement. It recalls a team owner who tells his coach to win a championship but fails to provide resources to make that happen. “Doing more with less” has never made sense. Ultimately, when one has less, all one can do is less.
Regarding that silver lining, CMS proposed a 3.9%, or $1.4 billion, Part A payment increase that is significantly higher than previous years. CMS also intends to add new metrics to its SNF VBP that rewards high-performing providers but penalizes those who fail to meet benchmarks through a sector-wide withholding. The additions include:
•Healthcare Associated Infections Requiring Hospitalization, an outcome measure that assesses performance on infection prevention and management.
•Total nursing hours per resident day, a structural measure that uses auditable electronic data to calculate total nursing hours per resident each day.
•Discharge to community, which will encourage SNFs to successfully discharge patients back to the community.
