CMS Finalizes PDPM Rule

August 2, 2018 LeadingAge DC Executive Director

The following information pertains to providers involved with Medicare reimbursement.

A CMS fact sheet on the final rule, effective October 1, 2018, is also available highlighting the three main provisions of the rule, those being the new case-mix classification system, the Patient-Driven Payment Model (PDPM), and policy updates to the SNF quality reporting program (QRP) and value-based purchasing program (VBP). Of note, CMS states that the rule “moves Medicare towards a more value-based, unified post-acute care payment system” which signals that this is likely foundational to the future concept of a unified post-acute care prospective payment system as mentioned in the IMPACT Act of 2014.

SNFs will receive a 2.4% payment update for FY 2019 based on the Bipartisan Budget Act of 2018. CMS took the recommendation of LeadingAge that organizations that failed to meet the QRP requirements have an update of 0.4% as opposed to -0.1% in the proposed rule with the 2% reduction for reporting noncompliance.

The PDPM proposal retains the implementation date of October 1, 2019. LeadingAge provided comments on the PDPM and other aspects of the proposed rule based on our analyses and input received from our members. CMS has indicated that information on training and education resources and opportunities associated with implementing the PDPM will be available on the CMS website at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/index.html. LeadingAge has joined other stakeholder groups in asking CMS for a PDPM stakeholder workgroup to proactively address transition and implementation challenge issues as well as aiding with education and dissemination of CMS guidance.

The Patient Driven Payment Model (PDPM) is a significant change for how Medicare is paying for skilled nursing. The focus on beneficiary clinical characteristics appears to be the clear direction of the future as CMS considers other payment systems, home health as an example, and post-acute care as a Medicare segment. LeadingAge will strive to ensure our members are positioned to transition successfully and in an educated manner.

As we analyze the final rule, we will provide additional information through multiple communication channels. LeadingAge is developing educational resources and opportunities for members and will be announcing initial resources in the coming weeks.