Preparing for Change

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Every year we know spring will arrive, but some years it seems a long time coming!  Like the long awaited change in weather, we have also been waiting for CMS to make their updates to the skilled nursing facility payment system. Granted the changes of spring are much more fun! 

Shortly after the implementation of a new payment system, PDPM, COVID struck our facilities, bringing on unimaginable challenges and heartache. Fortunately CMS gave our industry a reprieve at that time and did not make significant adjustments to the reimbursement system.  On April 11, 2022, CMS announced a proposed final rule to update how we do business in the long term care environment.  This proposed rule contains a mixed bag of revisions.

Although the new PDPM system appears to have cost 5% more than the previous payment system, CMS is considering a 4.6% parity adjustment, or reduction in reimbursement. Fortunately this decrease is somewhat offset by  a 3.9%  market basket update. Another revision includes ICD-10 mappings. Several codes now map to reimbursement categories when they previously did not. This may help offset the parity adjustment as well.  

On the clinical side, the definition of "isolation" may be expanded to inlcude cohorted residents. Costs and reimbursement for isolated residents are also under review. To adequatelly meet the needs of our residents, CMS is considering a bump up in minimun staffing requirements. This is a double edged sword for faciliities that are already struggling to hire enough STNAs to get the job done. Quality Reporting Programs may also be enhanced by reporting  percentages of staff receiving the influenza vaccination.  Additioanl QRP updates are being considered as well.  The Value-Based Purchasing program that rewards facilities financially for the quality of care they provide may also be updated. This program may have their benchmarks "zeroed out" to level the field and accommodate all facilities regardless of their re-hospitalization rates from COVID. Additional measures in future years are also proposed, including infection rates, patient discharges to the community and staffing turn over rates.  

The above is just the highlights of the many proposed changes for 2023. Like weeding out our gardens for the first time each spring, CMS, with stakeholder input, will weed out the least viable ideas and implement what is most likely to support quality, cost effective care for our residents in the years to come. Check out  https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2023-skilled-nursing-facility-prospective-payment-system-proposed-rule-cms-1765-p   for all the details. 

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