June 5, 2023
The Honorable Chiquita Brooks-LaSure Administrator
Centers for Medicare & Medicaid Services Department of Health and Human Services
Mail Stop C4–26–05
7500 Security Boulevard
Baltimore, MD 21244–1852023
Re: Medicare Program; 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; 88 Fed. Reg. 21,316 (April 10, 2023).
Dear Administrator Brooks-LaSure:2023
On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 700 skilled-nursing facilities (SNFs), and our clinician partners — more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2024 SNF prospective payment system (PPS) proposed rule.
The COVID-19 public health emergency (PHE) ended May 11, 2023; however, this does not mean that the health care system has returned to “pre-COVID” operations. Especially in the case of hospital continuum of care, of which SNFs are an important part, the health care system continues to reel from the effects of the pandemic and the extraordinary inflationary environment. Challenges facing the field include skyrocketing labor-costs, critical staffing shortages, and unprecedented rises in supply and drug costs. These have been felt by all providers, including hospital based and freestanding SNFs.
The AHA would like to stress to CMS the importance of SNFs’ role in the continuum of care, including on hospitals’ ability to properly care for and safely discharge patients in a timely manner. As SNFs and other post-acute providers have been strained by the pandemic, the ripple effects have been felt throughout the continuum of care. For example, a December 2022 report from AHA showed that the average length of stay (ALOS) for patients awaiting discharge to a SNF rose by more than 20% from 2019 to 2022.1 This increase is driven in large part by the difficulties SNFs and other post-acute providers have had in staffing and operating at full capacity. This, in turn, has limited hospitals’ capacity as hospital beds and resources remain dedicated to patients awaiting post-acute placement. Therefore, its vital to the entire health care continuum that CMS provide adequate reimbursement and resources to SNFs to help ensure all patients receive timely, appropriate care.
The AHA also would like to call out the unique experience and role played by hospital based SNFs during the PHE, which in some ways was notably different than their freestanding counterparts. Hospital-based SNFs’ connection to their host hospitals facilitated more robust infection control, improved access to personal protective equipment and other factors that affected their overall PHE response. That said, hospital based SNFs also faced immense challenges with each surge of the pandemic and its after-effects, including skyrocketing labor and supply costs, as well as acute labor shortages. Therefore, as CMS considers how to ensure SNFs are adequately resourced to care for Medicare beneficiaries, we ask that the agency pay special attention to these hospital based SNFs.
View the detailed letter below.