Proposed Updates for Skilled Nursing Facility Quality Reporting Program (SNF QRP) 

The SNF QRP creates SNF quality reporting requirements, as mandated by the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). On April 11, 2022, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update Medicare payment policies and rates for skilled nursing facilities (SNF) for the year 2023. This SNF PPS (Skilled Nursing Facility Prospective Payment System) includes proposals for the SNF Quality Reporting Program (QRP) and the SNF Value-Based Program (VBP) for FY 2023 and future years. This proposed rule CMS is publishing this proposed rule consistent with the legal requirements to update Medicare payment policies for nursing homes on an annual basis. 

What is the SNF QRP?

The SNF QRP creates SNF quality reporting requirements, as mandated by the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).  Every year, by October 1, CMS publishes the quality measures SNFs must report. The IMPACT Act requires the reporting of standardized patient assessment data with regard to quality measures and standardized patient assessment data elements. The Act requires the submission of data pertaining to quality measures, resource use, and other domains. In addition, the IMPACT Act requires assessment data to be standardized and interoperable to allow for the exchange of data among post-acute providers and other providers. The IMPACT Act intends to standardize post-acute care data to improve Medicare beneficiary outcomes through shared-decision making, care coordination, and enhanced discharge planning. If an SNF fails to submit the required quality data, the SNF will be subject to a two percentage (2%) point reduction in the Annual Payment Update (APU) for the applicable performance year.

Skilled Nursing Facility Quality Reporting Program (SNF QRP) Update

The SNF QRP is a pay-for-reporting program. SNFs that do not meet reporting requirements are subject to a two-percentage-point (2.0) reduction in their annual update. CMS is proposing to adopt one new measure for the SNF QRP. CMS is also proposing to revise the compliance date for certain SNF QRP requirements. In addition, CMS is proposing to revise the regulation text that pertains to data submission requirements for the SNF QRP. Finally, CMS is seeking comments on three Requests for Information (RFI).

Influenza Vaccination Coverage

Residents of long-term care facilities, who are often of older age, have a greater susceptibility to acquiring influenza due to general frailty and comorbidities, close contact with other residents, interactions with visitors, and exposure to staff who rotate between multiple facilities. Therefore, monitoring and reporting influenza vaccination rates among HCPs is important as HCPs are at risk of acquiring influenza from residents and exposing influenza to residents. 

CMS is proposing the adoption of a new process measure, the Influenza Vaccination Coverage among Healthcare Personnel (HCP) measure for the SNF QRP, beginning with the FY 2025 SNF QRP.  Given the fact that influenza vaccination coverage among HCPs is typically lower in long-term care settings, such as SNFs when compared to other care settings, CMS believes the proposed measure has the potential to increase influenza vaccination coverage in SNFs, promote patient safety, and increase the transparency of the quality of care in the SNF setting.  If adopted as proposed, SNFs will submit the measure data through the CDC National Healthcare Safety Network with an initial data submission period from October 1, 2022, through March 31, 2023.

Revised Compliance Date for Certain SNF QRP Requirements

CMS is proposing to revise the compliance date for certain SNF QRP reporting requirements including the Transfer of Health Information measures and certain standardized patient assessment data elements (including race, ethnicity, preferred language, health literacy, and social isolation) to October 1, 2023. The interim final rule with comment period that appeared on May 8, 2020, Federal Register (IFC-2) (85 FR 27550) delayed the compliance date for these items from October 1, 2020, to October 1st of the year is at least 2 full fiscal years after the end of the COVID-19 Public Health Emergency (PHE). CMS also delayed the adoption of the updated version of the Minimum Data Set (MDS), which is the assessment instrument providers would have used to collect the data.

This delay was intended to provide relief to SNFs during the COVID-19 PHE. However, based upon the advancement of information available about COVID-19 vaccination, treatments available, and the importance of the data in the SNF QRP, CMS believes that it would be appropriate to modify the compliance date finalized in IFC-2. It is also important to align the collection of this data with the Inpatient Rehabilitation Facilities and Long-Term Care Hospitals which will begin collecting this information on October 1, 2022, and Home Health Agencies which will begin collecting this information on January 1, 2023.

Inclusion of the CoreQ

Ensuring that patients and families are engaged as partners in their care can be an effective way to measure the quality of patient care. In this year’s proposed rule, CMS is requesting stakeholder feedback on the inclusion of the CoreQ: Short Stay Discharge measure in the SNF QRP in future program years, including whether there are any challenges or impacts we should consider for a potential future proposal. The CoreQ survey instrument is used to assess the level of satisfaction among SNF patients.

We shared these proposed updates for SNF QRP for reference only, you can visit below mentioned CMS links for a detailed understanding. MedicalBillersandCoders (MBC) is a leading medical billing company providing complete revenue cycle services. Our team keeps a close watch on revised billing guidelines to ensure accurate insurance reimbursements. To learn more about our complete Medical Billing and Coding Services for SNFs, contact us at info@medicalbillersandcoders.com/ 888-357-3226.

References: Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)