It's final: the US Centers for Medicare and Medicaid Services (CMS) is moving ahead with a rule governing skilled nursing facilities (SNFs) that's almost identical to what it proposed in April, including a change advocated for by APTA—a revised definition of what constitutes "group therapy" in SNFs. Aside from that alteration, it's a rule that hews to CMS' original plans to dramatically change the payment system for SNFs.
As anticipated, the final rule proceeds with implementation of the Patient-Driven Payment Model (PDPM). The model is based on a resident's classification among 5 components (including physical therapy) that are case-mix adjusted, and employs a per diem system that adjusts payment rates over the course of the stay. APTA has developed a number of resources on PDPM.
Other notable elements of the final rule:
- In a win for APTA and its members, CMS moved away from a rigid 4-person definition and adopted the association's recommendation that the definition of group therapy as 2 to 6 patients doing the same or similar activities—the same definition used in inpatient rehabilitation settings.
- The final rule adopts a "subregulatory" process to keep up with nonsubstantive updates to the ICD-10 codes used in PDPM, while substantive changes will be made through the traditional notice-and-comment rulemaking process.
- CMS will implement 2 new quality measures—transfer of health information to the provider-post-acute-care, and transfer of health information to the patient-post-acute-care—to be provided by the SNF at the time of transfer or discharge.
- The rule also adopts a number of standardized patient assessment data elements that assess cognitive function and mental status; special services, treatments, and interventions; medical conditions and comorbidities; impairments; and social determinants of health.
- CMS projects aggregate payments to SNFs will increase by $851 million, or 2.4%.