Premier Comments on Proposed FY 2023 Skilled Nursing Facility Rule

Premier commented on the FY 2023 skilled nursing facility (SNF) payment rule, calling for the Centers for Medicare & Medicaid Services (CMS) to:

• Wait to make any parity adjustment to the new Patient Driven Payment Model (PDPM), which was implemented just months before the public health emergency began, until a reliable analysis can inform an accurate recalibration;
• Focus on additional efforts to advance interoperability across the care continuum via electronic data exchange;
• Develop standards and measures for data exchange and sharing across all care settings, including SNFs;
• Incentivize SNFs to adopt electronic clinical surveillance technology to reduce and prevent healthcare associated infections;
• Consider adjustments to the SNF PPS in response to stakeholder input on how COVID affects the relative staff and time resources necessary for treating patients in isolation due to infection;
• Strengthen the completeness and quality of data submissions under the Quality Reporting Program (QRP) and include appropriate financial incentives to SNFs so they can invest in technologies that improve patient safety and compliance with data submission thresholds under the QRP;
• Withhold 0.0 percent for the SNF Value-based Purchasing (VBP) Program in FY 2023;
• Not consider the COVID-19 Vaccination Coverage Among Healthcare Personnel measure for future adoption at this time;
• Focus efforts on workforce improvement programs, rather than establishing unrealistic staffing requirements or penalizing SNFs for staffing turnover; and
• Address healthcare disparities through quality measure development.