AHA Comments on CMS Skilled Nursing Facility FY 2026 Proposed Payment

June 10, 2025

The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program for Federal Fiscal Year 2026; 90 Fed. Reg. 18,950 (April 30, 2025).

Dear Administrator Oz:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 500 skilled-nursing facilities (SNFs), 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) 2026 SNF prospective payment system (PPS) proposed rule.

SNFs play a critical role in the continuum of care; ensuring access to this frequently-utilized discharge destination is critical for patients continuing their recovery following a hospitalization. However, as the AHA highlighted in our comments on prior rulemakings, hospitals have faced increasing difficulty discharging patients to post-acute care, including SNFs. Staffing shortages and inadequate payment updates have contributed to the barriers to SNF care, as has the rapid expansion of beneficiary enrollment in Medicare Advantage (MA). The latter increases SNFs’ costs while reducing patient access and coverage, particularly through the inappropriate use of prior authorization. These shortfalls then place additional burden back on hospitals, which face extended lengths of stay for patients in need of post-acute care. While we appreciate that addressing concerns related to MA plans is outside of the scope of these comments, we encourage CMS to ensure that Traditional Medicare policies facilitate access to SNF services, rather than create barriers to care. Specifically, we urge CMS to provide adequate, timely payment updates for SNFs, including by re-examining the magnitude of its market basket updates and productivity adjustments.

Additionally, AHA appreciates CMS’ efforts to alleviate reporting burden on providers. Specifically, the AHA supports CMS’ proposal to remove four standardized patient assessment data elements (SPADEs) from the SNF QRP and greatly appreciates CMS’ recognition of the need to balance administrative burden and value in quality measurement programs. By streamlining reporting requirements, CMS can free providers to focus on the quality and safety issues that matter the most to their patients. In addition, the AHA provides in this comment letter an overview of its response to CMS’ Request for Information (RFI) on approaches and opportunities to streamline regulations and reduce administrative burdens on providers.

Our detailed comments follow.