Tuesday, June 9, 2020

AHCA Focuses on COVID-19 in SNF PPS Proposed Rule Comments

Today, AHCA submitted comments on the Fiscal Year 2021 Skilled Nursing Facility Prospective Payment System Notice of Proposed Rulemaking. All of AHCA’s comments focus on COVID-19 and ensuring patient and staff health and safety through accurate and adequate reimbursement.

In its comments, AHCA praises CMS for the Patient-Driven Payment Model (PDPM). Without PDPM’s focus on patient characteristics and related shift away from service-based metrics, specifically therapy minutes, we believe delivering care during the COVID-19 crisis would have been almost impossible. AHCA applauds CMS’ waiver flexibilities. The letter highlights AHCA’s related Interim Final Rule with Comments letters urging CMS to make its telehealth waivers permanent.

These have been critical to delivering care during the pandemic as well as to make much needed changes to the MDS guidance to allow two patients with COVID-19 to be placed in the same room. Other key comment areas include a request that CMS reweight and revise the market basket to reflect new, ongoing COVID-19 related costs and to work with the profession and Congress to add patient COVID-19 testing to consolidated billing. AHCA’s comments also note the profession’s focus on quality, highlighting that during the waiver of certain quality reporting requirements, we have continued to work with members on outcomes for patients and families.

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