AHCA/NCAL Submits Comment Letters to CMS On FY 2024 SNF PPS Proposed Payment Rule


Recently, the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) submitted two comment letters to the Centers of Medicare & Medicaid Services (CMS) regarding the “Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2024” (SNF Proposed Rule).  

The initial letter, submitted on May 26, 2023, AHCA/NCAL focused on an independently developed Milliman report, Qualitative Review of the CMS Skilled Nursing Facility Prospective Payment System Methodology commissioned by the Association, that provided a high-level review of the SNF PPS rate determination methodology.  Although Milliman did not author the report in response to the SNF Proposed Rule, the Association provided it as part of its comments to identify potential aspects that result in the PPS not being able to adequately adjust for sudden changes or shocks within the long term care community. Addressing the shortcomings of the SNF PPS is particularly relevant given the overwhelming impact caused by the COVID-19 pandemic and recent inflationary pressures to ensure that payment rates support SNF patients’ needs.  As CMS contemplates potential future changes in the SNF PPS rate setting methodologies that are within its authority, AHCA/NCAL hopes that this work is helpful in those deliberations.

In the second comment letter, submitted on June 1, 2023, the Association focus was on the remaining aspects of the proposed rule on which CMS requested comment including:
  • Consolidated Billing;
  • Technical Updates to PDPM ICD–10 Mappings;
  • Skilled Nursing Facility Quality Reporting Program (SNF QRP);
  • Skilled Nursing Facility Value-Based Purchasing Program (SNF VBP); and
  • Civil Money Penalties: Waiver of Hearing, Automatic Reduction of Penalty Amount

Finally, as AHCA/NCAL has done in recent years, the Association includes an extensive Appendix containing an independent Analysis of SNF Beneficiary Characteristics report commissioned from Avalere Health. The analysis details changes in the characteristics and case-mix of beneficiaries treated in SNFs using available data spanning 2019 through 2022 that may be important to consider for future payment policy decisions. The report includes figures, tables, and discussion from Avalere Health about notable trends that may be of interest to policymakers. The Appendix also includes a discussion about the potential causes and payment policy implications that CMS and other policymakers should consider when evaluating where the PDPM payment model and other policies may be headed in the future.