The Centers for Medicare & Medicaid Services’ proposed patient-driven payment model for skilled nursing facilities would increase overall payment accuracy, especially for the medically complex patients treated by hospital-based providers, but needs refinement, AHA told the agency in comments submitted today. “The AHA appreciates the extensive work CMS has done to develop an alternative to the current SNF case-mix system,” AHA wrote. “As noted in the rule, the current system has been widely criticized by policymakers for overly concentrating payments on cases with high-therapy utilization…However, our evaluation of the PDPM found that the model still has several flaws, which must be addressed before the PDPM proposal can be finalized.” In its FY 2019 proposed rule for the SNF prospective payment system, CMS proposes the model as an alternative to the current SNF case-mix system beginning in FY 2020.