CMS has made it clear in the SNF FY 2022 Proposed Rule, view full report, that PDPM was not budget neutral as originally anticipated, meaning that the new payment model would not result in an increase or decrease in SNF spending. With the recent data showing a 5% unintended increase in Medicare reimbursement for SNFs in FY 2020, CMS now states that a recalibration of the parity adjustment is needed to meet the initial goal of achieving budget neutrality.
When considering the increase, CMS does acknowledge the potential impact of the PHE for COVID-19 and the waivers have had on SNF reimbursement. They are seeking comments from stakeholders regarding the impact of COVID-19 on distribution of patient case-mix and overall utilization. There were some initial findings that were concerning regarding the potential impact of the PHE for COVID-19 on SNF utilization in FY 2020 which included the following:
While the data shows some impact to SNF operations, utilization, and average CMI, the overall impact of the PHE for COVID-19 was not enough to justify the significant impact to Medicare Reimbursement. Important questions to consider moving forward:
If your facility is having questions regarding waiver utilization and/or coding opportunities/ guidelines with COVID-19, our team of dedicated experts are available to answer any questions that you may have.