Tuesday, April 4, 2017

The SNF VBP Program

Courtney Bishnoi

On March 15, the Centers for Medicare and Medicaid Services (CMS) held a national provider call to review the Skilled Nursing Facility (SNF) Value-Based Purchasing (VBP) Program. The program, which will begin in fiscal year 2019 (i.e., October 1, 2018), rewards skilled nursing centers with incentive payments for their performance on the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM).

As defined by CMS, this measure estimates the risk-standardized rate of unexpected readmissions within 30 days for people with fee-for-service Medicare who were inpatients at PPS, critical access, or psychiatric hospitals for any cause or condition. The hospital readmissions are identified through hospital Medicare claims. Observation stays are not included in the SNFRM measure. It is important to note that this is a different measure than the one included in the Five-Star program.

The way this program works is that based on a SNFs rehospitalization rate in calendar year (CY) 2017 or improvement from CY 2015 to CY 2017, a SNF’s Medicare payment rates may be cut up to 2% for the entire year starting on October 1, 2018.

The baseline period for the SNFRM is CY 2015. This means that your current SNFRM performance is impacting your potential to avoid up to a 2% cut in all your Medicare Part A payments in FY 2019 (which starts on October 1, 2018). The SNF VBP scoring methodology uses both an achievement and an improvement score, defined by CMS as:
  • Achievement score: Points awarded by comparing the facility’s rate during the performance period (CY 2017) with the performance of all facilities nationally during the baseline period (CY 2015).
  • Improvement score: Points awarded by comparing the facilities rate during the performance period (CY 2017) with its previous performance during the baseline period (CY 2015).
SNF’s rehospitalization score is the better of their achievement score or their improvement score. How CMS will link the rehospitalization score to payment adjustments will be announced in the SNF PPS notice of proposed rulemaking expected out in May of 2017. 

While there are still some unknowns, we recommend SNFs try to prevent as many rehospitalizations as possible, since everyone is in the middle of the achievement score window (i.e., CY 2017).

CMS is required by section 1888(g)(5) of the Social Security Act to provide quarterly confidential feedback reports to SNFs on their performance on the SNFRM measure. CMS has begun to provide these confidential feedback reports via CASPER. The first complete report was distributed in December 2016 but is based on 2013 data. Newer reports only cover data through CY 2014. In the future, CMS will begin posting performance from CY 2015 and will also post this measure on Nursing Home Compare. To seek assistance in obtaining your SNF VBP feedback report, please contact the QIES Technical Support Office (QTSO) Help Desk: help@qtso.com.

CMS is seeking feedback on data elements that would be more useful than in the current quarterly feedback reports. To provide feedback to CMS, please contact SNFVBPinquiries@cms.hhs.gov. Alternatively, if you would like to send your feedback for AHCA to send to CMS, please email us at qualityinitiative@ahca.org.

Providers can learn more by accessing the slides from the March 15 call and listening to the recording, which will be available approximately two weeks after the event. Details can be found here.

Reducing rehospitalizations is a key component of the AHCA Quality Initiative. AHCA has resources to assist members in improving their readmission rates. To access free resources, members can visit the readmissions page of the Quality Initiative website and go to AHCA’s learning management website, ahcancalED, as well as LTC Trend Tracker.

If you have any questions, please contact us at qualityinitiative@ahca.org.

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