FY 2020 SNF PPS Final Rule Released

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

Late yesterday, July 30, 2019, CMS issued FY2020 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule – CMS-1718-F.  This SNF PPS Final Rule will take effect on October 1, 2019.  The Final Rule includes updates to the payment rates used under the SNF PPS for F2020.  Posting of the official Final Rule in the Federal Register is scheduled for August 7, 2019.  In the interim, you can review this 364-page unpublished PDF version.

The Fact Sheet, a great read outlining key elements, discusses three major provisions of the final rule:

  • SNF payment policy under the SNF Prospective Payment System (PPS)
  • SNF Value-Based Purchasing Program (VBP) and
  • SNF Quality Reporting Program (QRP)

Below are 3 paragraphs found beneath Summary of Major Provisions (pages 3 and 4) beneath the Executive Summary in the Final Rule (I’ve taken the liberty of bolding and italicizing key provisions – there’s a lot of them):

“In accordance with sections 1888(e)(4)(E)(ii)(IV) and (e)(5) of the Act, the federal rates in this final rule reflect an update to the rates that we published in the SNF PPS final rule for FY 2019 (83 FR 39162), as corrected in the FY 2019 SNF PPS correction notice (83 FR 49832), which reflects the SNF market basket update, as adjusted by the multifactor productivity (MFP) adjustment, for FY 2020. In addition, we are revising the definition of group therapy under the SNF PPS and implementing a subregulatory process for updating ICD-10 code lists used under the PDPM.  (Group therapy will be defined as “a qualified rehabilitation therapist or therapy assistant treating two to six patients at the same time who are performing the same or similar activities.”)

This final rule updates requirements for the SNF QRP, including the adoption of two Transfer of Health Information quality measures and standardized patient assessment data elements that SNFs would be required to begin reporting with respect to admissions and discharges that occur on or after October 1, 2020. We also are finalizing our proposal to exclude baseline nursing home residents from the Discharge to Community Measure. Further, we also are finalizing our proposal to publicly display the quality measure, Drug Regimen Review Conducted With Follow-Up for Identified Issues- Post Acute Care (PAC) Skilled Nursing Facility (SNF) Quality Reporting Program (QRP). We also are finalizing our proposal to revise references in the regulations text to reflect enhancements to the system used for the submission of data. Finally, we requested information on quality measures and standardized resident assessment data elements under consideration for future years, and we have summarized the information we received. In contrast, we are not finalizing our proposal to expand data collection for SNF QRP quality measures to all SNF residents, regardless of their payer.

In accordance with section 1888(h) of the Act, this rule updates certain policies for the SNF VBP Program.”

The Final Rule also speaks to PDPM, consolidated billing, payment for SNF-Level Swing-Bed services, CAHs, ICD-10 coding/ PDPM mapping, 5-day assessment will be referred to as initial Medicare assessment, IPA – the list goes on.

This Final Rule should be shared with your team as well as consultants and all individuals associated with SNF PPS activities in your facility.  There are now 61 days until October 1, 2019 – the start of PDPM as well as all things related to SNF PPS.  Time is moving quickly!