AHCA Submits PDPM Comments

Carl J. Pucci

AHCA has prepared extensive comments in response to the Patient-Driven Payment Model (PDPM), which is slated to replace the Resource Utilization Group (RUGs) Payment System on October 1, 2019.  AHCA will be developing member educational opportunities on PDPM once the 2019 SNF PPS proposed rule is finalized, which is expected in early August.

Please see AHCA's announcement below, which contains links to their comments:

Dear AHCA Member,

At you know, the Centers for Medicare & Medicaid Services (CMS) has proposed a new Skilled Nursing Facility Prospective Payment System (SNF PPS). The new payment system, called the Patient-Driven Payment Model (PDPM), would replace the Resource Utilization Group (RUGs) PPS entirely on October 1, 2019. It is as yet unclear if CMS' proposed implementation date is feasible.  

Movement from RUGs to PDPM would be the most significant change in SNF payment since the late 1990s. AHCA submitted two comment letters, an early letter submitted on May 24 emphasizing our key concerns and a formal, detailed comment letter yesterday. Both letters represent extensive member input and guidance on the part of AHCA's Reimbursement Committee, Clinical Practices Committee, Clinical and Performance Data Management Committee, and the Legal Committee.  

The June comment letter is one tactic of our PDPM advocacy strategy. In the coming weeks and months, AHCA will be meeting with a variety of senior CMS officials to emphasize our concerns, proposed solutions, and member priorities. We also will continue valuable collaboration with over 14 sister associations with whom we are working on PDPM advocacy.  

We hope you find this information useful. If you have questions, suggestions or concerns, please send me an email


Michael W. Cheek
Senior Vice President
Reimbursement Policy


Carl J. Pucci
Chief Financial Officer
518-462-4800 x36