Skilled nursing facilities can expect three finalized measures, along with several proposed measures for future years related to the value-based purchasing program, the Centers for Medicare & Medicaid Services (CMS) officials said Wednesday.
The various measures include stipulations connected to quality, staffing turnover, resident falls and discharges.
Chris Palmer, SNF VBP program coordinator with CMS, gave a quick overview of each measure related to VBP as outlined in the 2024 SNF Prospective Payment Systems’ (PPS) Proposed Rule, and encouraged providers to submit comments by June 5 via email or in writing by regular mail, express or overnight mail.
Two measures finalized by CMS in the 2023 SNF PPS Final Rule and due to be incorporated in 2026 include: SNF healthcare-associated infections requiring hospitalization (SNF HAI), and total nursing hours per resident day staffing.
Another finalized measure – discharge to community from post-acute care – is set to take effect in 2027.
Palmer didn’t go into much detail or answer questions during a webinar, citing the Administrative Procedures Act. Under this legislation, he wasn’t able to provide additional information, clarification or guidance on the measures.
Proposed VBP measures
Along with the three finalized measures, the VBP program is also proposing CMS adopt four new quality measures and replace one quality measure.
Proposals would also establish case minimum and measure minimum policies, incorporate a health equity adjustment (HEA), add scoring methodology for proposed measures, and update the SNF VBP validation process.
Palmer said the agency is proposing to replace the SNF 30-day all-cause hospital readmission measure (SNFRM) with the SNF within-stay potentially preventable readmission measure (SNF WS PPR) by 2028.
So far, the VBP program has only awarded incentive payments through its SNFRM measure as of 2019.
The replacement measure would estimate the risk-standardized rate of unplanned, potentially preventable hospital readmissions that occur among Medicare fee-for-service (FFS) beneficiaries during their SNF stay.
Crucially, the measure would also focus on potentially preventable and unplanned readmissions, while discounting planned readmissions. It would be calculated entirely using administrative data, Palmer said, and would not impose any additional data collection or submission burden on SNFs.
Perhaps unsurprisingly, given a looming proposed federal staffing minimum mandate, one of the proposed measures takes into account total nursing staff turnover. Turnover is already part of the Five-Star Quality Rating System.
“We are proposing to adopt the total nursing staff turnover measure beginning with the FY 2026 SNF VBP program year,” said Palmer. “Nursing home staffing, including nursing staff turnover, have long been considered an important indicator of nursing home quality.”
Palmer added that the measure would also drive improvements in nursing staff turnover, translating to positive resident outcomes, but didn’t get into more detail as to why that would be the case.
Another proposed measure – to be incorporated in 2027 – relates to the percentage of residents experiencing one or more falls with major injury and resulting in a long stay.
“Researchers found that [major] injury falls are one of the leading causes of disability and death for all nursing home residents,” Palmer said during the webinar. “Given the impact of falls with major injury, preventing and reducing their occurrence in SNFs is critical to delivering safe and high quality care.”
While major injury falls is a long-stay metric, Palmer said the measure would be a good way to capture care provided to the whole population residing in facilities, especially those that are dually certified as SNF and nursing homes. In other words, providers that care for short-stay and long-term residents.
Discharge and hospitalization measures
Two other proposed measures deal with discharge function and the number of hospitalizations per 1,000 long-stay resident days, both with a suggested starting year of 2027.
The discharge function measure would estimate the percentage of SNF residents who meet or exceed an expected discharge score during the reporting period, Palmer said. The score would be calculated based on “individual function items” at discharge and take into account age and clinical condition.
“Impaired functional capacity is associated with poor quality of life and an increased risk of all-cause mortality, post-operative complications and cognitive impairment later, which can complicate the return of residents to the community from post-acute care,” noted Palmer.
This particular measure may also be part of the SNF Quality Reporting Program, he said.
Concerning the hospitalizations per 1,000 long-stay resident days, Palmer again said such a long-stay measure better captures the entire population at facilities that are dually certified as SNFs and nursing homes. It’s also an indicator that the facility performs better on other “dimensions of quality,” he said, including surveys, staffing level goals and other quality measures.
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