AHA Comments on Skilled Nursing Facility Proposed Rule For FY 2022

American Hospital Association comments on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2022 proposed rule on the SNF prospective payment system (PPS). This letter focuses on the payment provisions that would be affected by COVID-19-driven dynamics, as well as several key proposals related to quality reporting, and the agency’s requests for information on health equity and digital quality reporting.

In addition to the issues discussed in this letter, the AHA expresses sincere thanks to the agency for the elements in the proposed rule that demonstrate CMS’ active support of the field at this critical time. For example, we particularly appreciate the agency’s decision to not yet propose an addition to the “parity adjustment” designed to ensure budget neutral implementation of the new case-mix system, known as Patient Driven Payment Model (PDPM), in FY 2020, and to confirm that any future adjustment would be implemented on a prospective basis. These positions give the SNF field the much-needed space to address the devastating effects of the pandemic, including retooling personnel training and clinical protocols, implementing physical plant modifications, and other actions to enhance competencies and secure patient safety. View the entire letter below.