Premier Comments on the FY 2024 Skilled Nursing Facility Proposed Rule

Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the fiscal year (FY) 2024 Skilled Nursing Facility (SNF) proposed rule.

In its detailed comment letter, Premier urges CMS to:

• Focus on additional efforts to advance interoperability by developing standards and measures for data exchange and sharing across all care settings, including skilled nursing facilities (SNFs), via electronic data exchange;
• Explore policy options to incentivize SNFs to adopt electronic clinical surveillance technology to reduce and prevent healthcare associated infections (HAIs);
• Consider the burden associated with COVID-19 vaccination measures, especially in light of CMS revoking COVID-19 vaccination mandates for healthcare workers.
• Move forward with a health equity adjustment (HEA) to the SNF Value Based Purchasing (VBP) program while continuing to test, refine and advance additional measures that produce a valid HEA for the VBP;
• Field a request for information (RFI) to solicit stakeholder feedback on the potential development of a program to enable the provision of SNF services in the home; and
• Analyze the impact of waiving the SNF 3-day stay requirement during the public health emergency (PHE) versus its reimplementation post-PHE, focused on cost and patient outcomes, to inform policymaking on the future of this requirement.