CMS Released the FY 2024 SNF PPS Final Rule
CMS released the FY 2024 SNF PPS Final Rule. Let’s cut to the chase – what do providers need to know? The Centers for Medicare and Medicaid Services (CMS) issued the Fiscal Year (FY) 2024 final rule for Skilled Nursing Facilities (SNFs) Prospective Payment System late Monday (7/31/23) afternoon. Among its 451 pages, key takeaways will have an impact on nursing home budgets.
Medicare Payments Increase 4%
CMS estimates the impact of this final rule will increase Medicare Part A aggregate payments to SNFs by 4%, or $1.4 billion, in FY 2024. This increase includes the 2.3% decrease due to the remaining parity adjustment promised by CMS for FY 2024.
While this is certainly beneficial for SNFs, the reality is, this increase still may not cover the gap of rising expenses for all providers; and looming minimum staffing standards would further dampen the market basket increase’s positive impact.
Changes to SNF QRP and SNF VBP Rolling into Effect for Years
The final rule included numerous edits to the SNF Quality Reporting Program (SNF QRP) and SNF Value Based Purchasing (SNF VBP) program. With changes mapped out through FY 2028, providers need to assess their current state; how SNFs report and perform beginning in FY 2024 will impact their outcome in future program years. Providers can also download their FY 2024 SNF VBP August 2023 Performance Score Reports (PSRs) now via iQIES; which will include the incentive payment multiplier applied to FY 2024 Medicare payments.
A proposed change worth noting, the Total Nursing Staff Turnover measure was proposed for the FY 2026 SNF VBP program. Industry leaders have questioned this measure, calling out discrepancies between CMS’ definition of gaps in employment (60 days) and the Department of Labor’s family/medical leave (12 weeks per year).
| SNF QRP Measure Changes | Status | Program Year |
| Transfer of Health Information to the Patient Post-Acute Care (PAC) measure | Public Reporting Policy Modified | FY 2025 |
| Transfer of Health Information to the Provider-PAC measure | Public Reporting Policy Modified | FY 2025 |
| Discharge Function Score measure | Public Reporting Policy Modified | FY 2025 |
| COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure | Public Reporting Policy Modified | FY 2026 |
| COVID-19 Vaccination Coverage among Healthcare Personnel Measure | Modified | FY 2025 |
| Discharge Function Score Measure | Adopted | FY 2025 |
| Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function measure | Removed | FY 2025 |
| IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients measure | Removed | FY 2025 |
| IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients measure | Removed | FY 2025 |
| COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure | Adopted | FY 2026 |
| SNF QRP data completion thresholds for the Minimum Data Set (MDS) data items | Modified | FY 2026 |
| SNF VBP Measure | Status | First Program Year | First Performance Period |
| SNF 30-Day All-Cause Readmission Measure | Adopted, implemented | FY 2017 | FY 2015 |
| SNF Healthcare-Associated Infections requiring Hospitalization Measure | Adopted, not implemented | FY 2026 | FY 2024 |
| Total Nurse Staffing Hours per Resident Day Measure | Adopted, not implemented | FY 2026 | FY 2024 |
| Total Nursing Staff Turnover Measure | Proposed | FY 2026 | FY 2024 |
| Discharge to Community- Post-Acute Care Measure for SNFs | Adopted, not implemented | FY 2027 | FY 2024 and FY 2025 |
| Percent of Residents Experiencing One or More Falls with Major Injury (Long-Stay) Measure | Proposed | FY 2027 | FY 2025 |
| Discharge Function Score for SNFs Measure | Proposed | FY 2027 | FY 2025 |
| Number of Hospitalizations per 1,000 Long Stay Resident Days Measure | Proposed | FY 2027 | FY 2025 |
| SNF Within-Stay Potentially Preventable Readmissions Measure | Proposed | FY 2028 | FY 2025 and FY 2026 |
With significant changes going into effect for FY 2024 – partner with Celtic, a post-acute advisory firm, delivering operational, clinical, and financial support to healthcare providers.
Celtic frequently provides operational assessments to reveal barriers to reimbursement success, and Quality Measure reviews to determine and address opportunities for improvement. By engaging our clients in multi-prong action plans, we have assisted in providers sustaining gains with multiple payment sources.
When every dollar counts, count on Celtic. Our team of subject matter experts make sure you don’t miss an opportunity. Contact us today to discuss your options.
