Proposed Changes to the Skilled Nursing Facility Quality Reporting Program

The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule to update the Medicare payment policies and rates for skilled nursing facilities under the Skilled Nursing Facility Prospective Payment System (SNF PPS). The proposed rule also includes proposals for the SNF Quality Reporting Program (QRP) and the SNF Value-Based Purchasing program for fiscal year 2024 and forward. The Biden-Harris administration has taken steps throughout its time in office to improve the safety and quality of care in nursing homes and the transparency of nursing home data. While the CMS is legally required to update the Medicare payment policies for SNFs annually, these updates to the SNF QRP also support the Administration’s plans regarding nursing home transparency.

The SNF QRP program creates reporting requirements that all SNFs must abide by. The data collected is then made public through the Care Compare website. These reporting requirements were mandated by the Improving Medicare Post-Acute Care Transformation Act of 2014, and the data collected from SNFs are published every October 1. If an SNF fails to submit the required quality data, they are subject to a two percent (2%) point reduction in the Annual Payment Update for the performance year. With the fiscal year 2024 Proposed Rule, the CMS is proposing the adoption of three measures, the removal of three measures, and the modification of one measure to the SNF QRP.

Based on the CMS press release, the measures which are proposed to be added, updated, and removed are as follows:

1. Adoption of the Discharge Function Score measure – per the CMS: “this measure assesses functional status by assessing the percentage of SNF residents who meet or exceed an expected discharge function score, and uses mobility and self-care items already collected on the Minimum Data Set (MDS).” This measure would begin with the fiscal year 2025 SNF QRP.
2. Adoption of the CoreQ: Short Stay Discharge measure – per the CMS: “this measure calculates the percentage of individuals discharged from an SNF, within 100 days of admission, who are satisfied with their SNF stay.” To obtain this data, the SNF will have to send patients a questionnaire that asks them to measure the individual’s overall satisfaction using a 5-point Likert scale. This measure would begin with the fiscal year 2026 SNF QRP.
3. Adoption of the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure – per the CMS: “This measure reports the percentage of stays in which residents in an SNF are up to date with recommended COVID-19 vaccinations in accordance with the Centers for Disease Control and Prevention’s (CDC’s) most recent guidance.” This measure would begin with the fiscal year 2026 SNF QRP.
4. Modification of the COVID-19 Vaccination Coverage among Healthcare Personnel measure – per the CMS: “This measure tracks the percentage of healthcare personnel working in SNFs who are considered up to date with recommended COVID-19 vaccination in accordance with the CDC’s most recent guidance.” Previously, this measure only reported on whether the provider had received the primary vaccination series. The updated measure would begin with the fiscal year 2025 SNF QRP.
5. Removal of the Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function measure – per the CMS, they are proposing removal for two reasons: “First, the measure performance among SNFs is so high and unvarying that meaningful distinctions in improvements in performance can no longer be made. Second, there is an available measure (the proposed DC Function measure, discussed above) that is more strongly associated with desired resident functional outcomes.” This measure will be removed beginning with the fiscal year 2025 SNF QRP.
6. Removal of the Application of the IRF Functional Outcome Measures: Change in Self-Care Score for Medical Rehabilitation Patients measure; and the Change in Mobility Score for Medical Rehabilitation Patients measure – per the CMS, they are proposing removal because “the costs associated with a measure outweigh the benefits of its use in the program. Additionally, these measures are similar or duplicative of other measures within the SNF QRP.” These measures will be removed beginning with the fiscal year 2025 SNF QRP.

Per the CMS press release, another proposed change is “to increase the SNF QRP Data Completion thresholds for the Minimum Data Set Data Items beginning with the FY 2026 SNF QRP.” With this update, SNFs must report 100% of the required quality measure data and standardized resident assessment data collected using the MDS on at least 90% of the assessments they submit to CMS. If they do not meet these requirements, the SNF will be subject to a reduction of 2 percentage points to the applicable annual payment update.

The full proposed rule can be viewed on the Federal Register website, along with instructions on how to make public comments. The CMS is taking public comments until June 5, 2023.

Proper reporting is an integral part of managing a SNF. SNF leaders must ensure they meet the reporting requirements of the SNF QRP to receive the maximum amount of funding possible. If you have any questions about properly reporting your data and ensuring that you are receive maximum funding, please reach out to Marcum’s healthcare team.