CMS Posts FY2021 SNF PPS Proposed Rule

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

Late in the day on Friday, April 10, 2020, CMS posted the public inspection copy of the FY2021 SNF PPS Proposed Rule – CMS-1737-P.  This 93-page document is scheduled to be published in the Federal Register on April 15, 2020 online at on that date.

Stakeholder comments are due to CMS no later than 5 PM on June 9, 2020.   

Here’s the Table of Contents for the proposed rule:

  1. Executive Summary
  2. Purpose
  3. Summary of Major Provisions
  4. Summary of Cost and Benefits
  5. Advancing Health Information Exchange
  6. Background on SNF PPS
  7. Statutory Basis and Scope
  8. Initial Transition for the SNF PPS
  9. Required Annual Rate Updates

III. Proposed SNF PPS Rate Setting Methodology and FY 2021 Update

  1. Federal Base Rates
  2. SNF Market Basket Update
  3. Case-Mix Adjustment
  4. Wage Index Adjustment
  5. SNF Value-Based Purchasing Program
  6. Adjusted Rate Computation Example
  7. Additional Aspects of the SNF PPS
  8. SNF Level of Care–Administrative Presumption
  9. Consolidated Billing
  10. Payment for SNF-Level Swing-Bed Services
  11. Revisions to the Regulation Text
  12. Other Issues
  13. Proposed Changes to SNF PPS Wage Index
  14. Technical Updates to PDPM ICD-10 Mappings
  15. Skilled Nursing Facility Value-Based Purchasing Program (SNF VBP)
  16. Collection of Information Requirements

VII. Response to Comments

VIII. Economic Analyses

  1. Regulatory Impact Analysis
  2. Regulatory Flexibility Act Analysis
  3. Unfunded Mandates Reform Act Analysis
  4. Federalism Analysis
  5. Reducing Regulation and Controlling Regulatory Costs
  6. Congressional Review Act
  7. Regulatory Review Costs

The corresponding Fact Sheet contains these statements regarding the Proposed Rule (bolding and italics added by me):

  • CMS is publishing this proposed rule consistent with the legal requirements to update Medicare payment policies for skilled nursing facilities on an annual basis.
  • The proposed rule includes proposals required by statute and that affect Medicare payment to SNFs, as well as proposals that reduce provider burden and may help providers in the COVID-19 response.
  • These updates include routine technical rate-setting updates to the SNF PPS payment rates, as well as a proposal to adopt the most recent Office of Management and Budget (OMB) statistical area delineations and apply a 5 percent cap on wage index decreases from FY 2020 to FY 2021. We are also proposing changes to the ICD-10 code mappings that would be effective beginning in FY 2021, in response to stakeholder feedback. Finally, this rule includes minor administrative proposals related to the SNF Value-Based Purchasing (VBP) Program. CMS is not proposing to make any changes to the measures, SNF VBP scoring policies, or payment policies.
  • CMS projects aggregate payments to SNFs will increase by $784 million, or 2.3 percent, for FY 2021 compared to FY 2020. This estimated increase is attributable to a 2.7 percent market basket increase factor with a 0.4 percentage point reduction for multifactor productivity adjustment.