CMS releases FY 2019 proposed rule, includes RCS-1 replacement

CMS has posted a proposed rule for FY 2019. The proposal not only changes payment rates, but also proposes a new case mix grouping called the Patient-Driven Payment Model, or PDPM. This model replaces the RCS-1 that was proposed in May of last year. According to CMS, this new system has 80% fewer groupings and uses some metrics already collected for quality reporting. CMS says the intention is to lessen administrative burden, streamline the process, and provide payment equal to care needs of the patient rather than volume of patients. PDPM would be effective October 1, 2019.

PDPM addresses the ability to change a resident’s case mix group over the duration of his or her stay—a component that was static in RCS—as well as the ability to record the amount of therapy provided to a resident, information that was not accounted for in RCS. One significant complaint from commenters on the proposed RCS model was its lack of ties to the IMPACT Act and other major laws; PDPM would incorporate patient assessment information from Section GG rather than Section G, creating a necessary link between points outlined in the requirement.

The rule also changes the market basket rate to 2.4%, required by the recent Bipartisan Budget Act of 2018. CMS estimates that the FY 2019 aggregate impact will be an increase of $850 million in Medicare payments to SNFs. Mark Parkinson, President and CEO at the American Health Care Association (AHCA) says this rate increase is “critical for providers who are struggling to make ends meet and keep their doors open.”

The final rule does not add measure to the Quality Reporting Program (QRP). As far as the Value-Based Purchasing (VBP) program, the proposed rule updates policies, including the performance and baseline periods for the FY 2021 SNF VBP Program year, an adjustment to the SNF VBP scoring methodology, and an Extraordinary Circumstances Exception (ECE) policy.

Comments on the proposed rule are due by June 26, 2018. CMS will also hold an open door forum on Tuesday, May 1, 2pm ET, to answer stakeholders’ questions about the revised model and additional proposed rule details.

On a lesser note, the proposed rule also asks stakeholders to comment on “on positive solutions to better achieve interoperability or the sharing of healthcare data between providers. Specifically, CMS is requesting stakeholder feedback through a RFI on the possibility of revising Conditions of Participation related to interoperability as a way to increase electronic sharing of data by providers.” However, this will not be addressed in the final rule. Rather, the comments will direct future rule-making.

Find more information, including fact sheets and a technical report on PDPM, at www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-04-27-4.html.

Post-Acute Advisor readers, PPS-Alert subscribers, and members of Biller’s Association for Long-Term Care will all be informed on an ongoing basis as the impact of this proposed rule reveals itself. Watch for future posts here for an in-depth breakdown of the rule, particularly PDPM.

Leave a Reply

Your email address will not be published. Required fields are marked *

*