Commenting on the fiscal year 2017 proposed rule for the skilled nursing facility prospective payment system, the AHA today encouraged the Centers for Medicare & Medicaid Services to fully consider refinements recommended by the Medicare Payment Advisory Commission as it works to develop a new SNF payment model. The recommendations, which AHA said would improve the fairness of payments for hospital-based SNFs, include paying for SNF services based on patients’ clinical characteristics rather than on therapy utilization; adding a per-stay, high-cost outlier policy to the SNF PPS; and establishing a separate payment for non-therapy ancillary services. The letter also address the proposed rule’s quality reporting provisions, which call for three new measures for the FY 2018 SNF quality reporting program. “While the AHA appreciates that CMS proposes these measures to fulfill its statutory requirements under the IMPACT Act, we believe all three need significant improvement prior to their implementation,” wrote AHA Executive Vice President Tom Nickels.