CMS Issues 2017 SNF PPS Proposed Rule

Carl J. Pucci in Clinical & Quality

CMS has issued the 2017 SNF PPS proposed rule, which provides for a net market basket increase of 2.1% (approximately $800M), effective 10/1/16.

In addition to the rate increase (which will fluctuate based on a facilities regional wage index), members are alerted to the SNF Value Based Purchasing program (SNF VBP) which establishes a 2% withhold to Part A payments (effective 10/1/18) that can be earned back based on re-hospitalization rates and levels of improvement.  (VBP performance period currently proposed through calendar year 2017).

NYSHFA/AHCA will be closely monitoring reaction to the proposed rule, and once the Final Rule is published later this summer, we will then calculate the 2016/17 SNF PPS rates.

Below is AHCA’s announcement of the rule, including links to the proposed rule and AHCA summary.

Dear AHCA Member:

The Centers for Medicare & Medicaid Services (CMS) today issued the proposed rule for the skilled nursing facility (SNF) prospective payment system (PPS) fiscal year (FY) 2017 update.

We are pleased to report that the proposed rule includes a net market basket increase of 2.1 percent. CMS is holding off another year on a major overhaul of the payment system for SNF, and instead, proposing a PPS update tied with updates in quality measures. The FY 2017 proposed rule continues to advance the integration of payment policy and quality-related provisions with payment and quality reporting, producing new implications from the proposed rule for SNFs. 

AHCA will archive last Friday’s webinar later this week.  Attached is the webinar PowerPoint.

Specifically, the FY 2017 rule further develops proposals for implementation of the Protecting Access to Medicare Act of 2014 SNF rehospitalization program and includes the second set of proposed measures mandated by the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). Going forward, the profession will see additional quality provisions in its payment rules.

AHCA has also created a summary with highlights and a preliminary overview of the payment updates, the SNF value-based purchasing program proposed new components, and the IMPACT Act quality reporting additions. A more detailed summary will be shared early next week. Comments, suggestions and questions may be directed to Mike Cheek.

Highlights 

  • The proposed rule provides for a net market basket increase for SNFs of 2.1 percent beginning October 1, 2016.
  • The 2.1 percent market basket update reflects a full market basket increase of  2.6 percent reduced by 0.5 percentage points, in accordance with the multifactor productivity adjustment required by Section 3401(b) of the Affordable Care Act (ACA). No forecast error was incurred.  
  • The market basket 2.1 percent for FY 2017 for the SNF PPS is based on the IHS Global Insight, Inc. (IGI) first quarter 2016 forecast with historical data through fourth quarter 2015. This figure could change when CMS issues the final rule based on more recent IGI data.
  • CMS estimates that the net market basket update would increase Medicare SNF payments by approximately $800 million in FY 2017.
  • As noted above, a forecast error correction was not needed. Since the difference between the estimated and actual amount of change in the market basket index was below the 0.5 percentage point threshold in FY 2015, the payment rates for FY 2017 are not impacted by the current IGI data. 
  • In accordance with the Medicare Modernization Act (MMA), the per diem rate for SNF patients with Acquired Immune Deficiency Syndrome (AIDS) had been increased by 128 percent as of October 1, 2004. Under the CMS proposed rule, this add-on will remain in effect for FY 2017. 
  • As noted earlier, the Skilled Nursing Facility VBP Program (SNF VBP) is discussed. Establishment of the program, which implements a 2 percent withhold to SNF Part A payments that can be earned back based on a SNF's rehospitalization rate and level of improvement, is required by the Protecting Access to Medicare Act of 2014 (PAMA). CMS proposes that the performance period be based on the calendar year starting January 1, 2017.
  • Additionally, CMS proposes four new measures for the Quality Reporting Program (SNF QRP). They are drug regimen review, average cost per Medicare beneficiary, rehospitalization rate, and discharge to community rate.   


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NYSHFA CONTACT:

Carl J. Pucci
Director, Finance & Reimbursement
518-462-4800 x36