CMS finalized its 2027 Skilled Nursing Facility Prospective Payment System (SNF PPS) rule, increasing rates by 2.4%, but nursing home leaders say the shortened clinical data reporting window will increase administrative burdens.
The agency’s decision is based on the final SNF market basket of 3.3%, reduced by a 0.9% productivity adjustment for an estimated increase of $882.74 million in aggregate payments to nursing homes.
Notably, data submission changes were baked into the SNF PPS. The SNF Quality Reporting Program (QRP) now requires that operators submit Minimum Data Set (MDS) data for all residents regardless of payer. CMS says this will align the SNF QRP with other post-acute care settings and agency programs that already collect data on all patients regardless of payer.
Associations including the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) and LeadingAge weighed in on the matter, with the former worried the move will exacerbate administrative burdens, while the latter sees the change in data collection as a positive.
“We are concerned that expanding the SNF Quality Reporting Program to all residents regardless of payer source will drastically increase administrative burden without directly improving clinical care for patients,” Clif Porter, AHCA/NCAL president and CEO, said in a statement. “We remain committed to working with CMS on policies that further invest in strengthening access to high-quality post-acute care while streamlining reporting in order to put patients before paperwork.”
Jodi Eyigor, vice president of health policy for LeadingAge, said an all-payer data approach is something the association has long advocated for.
“We fully support requiring submission of minimum data set (MDS) data on all skilled nursing facility residents admitted for skilled care regardless of payer because the outcome will be a more complete picture of provider performance and outcome,” said Eyigor.
Revised SNF QRP data submission must be done in 45 days as well, CMS said, a much shorter timeframe compared to the previous 4.5 month timeslot. The new timeframe begins with the 2029 SNF QRP.
CMS is also finalizing the removal of two Covid-related quality measures: Covid vaccination coverage among healthcare personnel, and the percentage of patients and residents up to date on their Covid vaccine.
“Our opposition to these is longstanding: both reflect personal choice and do not reflect or measure quality of nursing home care,” said Eyigor. “That’s even more true now, with the Centers for Disease Control and Prevention recommendations having changed to shared clinical decision-making. Measuring uptake just doesn’t make sense.”
As for new quality measures under SNF QRP, advanced care planning continues to be up for discussion, CMS said. The measure would track conversations and documentation aligning a patient’s care and interventions with their beliefs, values and preferences if they become unable to make those decisions.
CMS issued a Request for Information (RFI) to potentially update the Patient Driven Payment Model payment system to address case-mix upcoding. It’s a broader effort to ensure payment policy reflects current care practices and changes in resident population, CMS said.
CMS finalized SNF Value-Based Purchasing (VBP) performance standards for 2029 and 2030 as part of the rule as well, and updated the snapshot date for two measures calculated using MDS assessment data, to maintain alignment with SNF QRP submission deadlines. Updates will start with 2027 data.
Administrative and financial burdens
After rising operating costs are considered, many skilled nursing facilities will see a much smaller financial benefit after sequestration, VBP withholds and potential QRP penalties, according to Jessie McGill, senior curriculum specialist at the American Association of Post-Acute Care Nursing (AAPACN).
The shortened window to report the MDS and infection-control data will also add to burdens for staff, McGill said.
Starting October 1, 2029, facilities must collect MDS data for all residents receiving covered skilled care, regardless of payer, for the FY 2031 QRP. This significantly expands reporting responsibilities, requiring SNFs to track skilled coverage, payer changes and assessment timing.
CMS has underestimated the administrative burden and remains concerned about how the expanded data may eventually be used in quality measures and public reporting, McGill told Skilled Nursing News.
“The work extends beyond entering MDS data. It includes reviewing the resident’s clinical needs, monitoring skilled coverage, coordinating assessment dates, conducting interviews, communicating across departments, and using clinical judgment to determine when reporting requirements are triggered,” she said. “These responsibilities cannot simply be automated or absorbed by technology.”
Facilities with high Medicare Advantage enrollment, frequent payer changes or limited MDS resources may face the greatest challenges, McGill noted.
(Editor Zahida Siddiqi contributed to the reporting of this article.)
Companies featured in this article:
AHCA/NCAL, American Health Care Association, Centers for Medicare & Medicaid Services, CMS
