Premier Submits Comments on CY 2027 Skilled Nursing Facility Proposed Rule

Premier submitted comments on the FY 2027 Medicare Skilled Nursing Facility (SNF) proposed rule. In our detailed comments, Premier recommends that CMS:

• Develop a process and methodology that directly and accurately captures SNF wage costs;
• Advance a comprehensive approach to the transfer of health information by focusing on additional efforts for interoperability across the care continuum, including SNFs, via electronic data exchange;
• Incentivize SNFs to adopt electronic clinical surveillance technology to reduce and prevent healthcare associated infections;
• Develop standards and measures for data exchange and sharing across all care settings, including SNFs;
• Establish a SNF Quality Reporting Program (QRP) data submission process that provides SNFs with adequate time to meet any new submission timeline requirements, especially in the first several cycles when new timeline requirements are implemented;
• Ensure SNFs have adequate resources and processes in place prior to implementing requirements for minimum data set QRP submissions for all residents, regardless of payer; and
• Implement a Value-Based Purchasing program methodology that will result in a 70 percent payback percentage each year.