On April 27th, the Centers for Medicare & Medicaid Services (CMS) released an Advance Notice of Proposed Rulemaking that solicits comment on potential revisions to the Medicare skilled nursing facility (SNF) payment system, based on research conducted under the SNF Payment Models Research project.
The recommendation that CMS is seeking comment on is a proposed shift away from the current resource utilization groups (RUG-IV) to a new resident classification system (RCS-I). Essentially, this would expand the three categories currently in place – therapy, nursing, and non-case-mix – to five categories – occupational and physical therapy (OT+PT), speech language pathology (SLP), nursing, non-therapy ancillary (NTA), and non-case-mix – in the recommended system.
Acumen conducted an impact analysis to study the effect RCS-I would have on various resident and provider subpopulations. The analysis compared actual fiscal year (FY) 2014 payments under RUG-IV to what FY 2014 payments would have been had RCS-I been in place. Both RUG-IV and RCS-I payments were calculated including the 2% reduction in Medicare payments under budget sequestration, which was in effect in FY 2014. According to their research, the most notable impact of RCS-I would be to shift payments associated with residents receiving very high amounts of therapy under RUG-IV (which strongly incentivizes the provision of therapy) to residents with complex clinical needs. Acumen estimates that various provider subpopulations would also receive higher payments, including non-profits, government-owned facilities, hospital-based facilities, swing bed providers, and small facilities.
The theme of paying for the cost of care associated with patient characteristics is a long held position of LeadingAge. If the impact analysis holds true, this proposal could be beneficial to many LeadingAge members with SNF capacity. However, many details of the proposal warrant further review. LeadingAge will be examining the proposal and offering comments to CMS. We encourage interested members to contact LeadingAge (atripp@leadingage.org) if they want to have ideas or comments incorporated into the LeadingAge comment letter by June 19, 2017.
