SNF and the Social Determinants of Health

by Tiffany Ferguson, LMSW, CMAC, ACM
Published on Apr 20, 2022

Article published April 20, 2022 on

Last week, the Centers for Medicare & Medicaid Services (CMS) followed up on President Biden’s request to address the quality and delivery of care in skilled nursing facilities (SNFs). CMS issued a proposed rule that would update Medicare payment policies and rates for the 2023 fiscal year, and also introduced proposals for new data requirements for the SNF Quality Reporting program (QRP) and the SNF Value Based Program.

Essentially, the proposed rule is a bigger ask for skilled facilities, with less money available to do it. 

To assure budget neutrality, CMS is proposing to decrease SNF payments by 4.6 percent, which equates to about $1.7 billion. The adjustment is coming as a recalibration of the case-mix classification model also known as the Patient-Driven Payment Model (PDPM), which went into effect in late 2019. CMS had hoped that payments in the new model would lead to a decrease in charges and spending for skilled facilities, or at least neutrality from the old Resource Utilization Group (RUG) system; however, the change created an opposite effect, with an unintended increase in 5 percent of payments during 2020. The intended goal of this transition is to ensure that skilled nursing facilities are aligned with a patient-focused model, rather than a model based on numbers of services, such as amount of time completing physical therapy. The difficulty with this proposal is the historical reality of this time of calculation was during COVID, and forgive my frankness, but “no duh,” we used more SNFs during COVID, and they absolutely took care of sicker patients.

OK – now for the other items in the proposed rule include the following:

  1. Proposed changes for the PDPM ICD-10 code mapping categories for physical therapy (PT), occupational therapy (OT), speech, and non-therapy ancillary services;
  2. A request to add specific coding for patients who are in SNF infection isolation, with specific classifications for criteria to meet;
  3. A request for input on the effects of direct care staffing, which include nursing, nursing assistants or aids, and other professionals, with specific intent to determine a minimum required staffing level. They are also looking at a potential SNF value-based purchasing measure to look at facility staffing turnover;
  4. CMS is looking to add influenza vaccination coverage rates among facility healthcare personnel as a new measure to the SNF Quality Reporting Program, which begins in FY 2025; and
  5. CMS is requesting to no longer delay the updated Minimum Data Set requirements, which include the transfer and standardization of data elements for race, ethnicity, preferred language, health literacy, and social isolation levels. This ties to their intent to increase reporting on health disparities, and to determine how to target future programs to address these concerns across the country.

So, what is the impact your organization could experience as a result of the Skilled Nursing Facility Prospective Payment System proposed rule?

To see the results from listeners during this week’s Monitor Mondays click here.