AHCA Member Summary of FY 2025 SNF Final Payment Rule

Regulations; Reimbursement
 

​​Yesterday, the Centers for Medicare and Medicaid Services (CMS) issued the final rule​ for the skilled nursing facility (SNF) prospective payment system (PPS) fiscal year (FY) 2025 update.

​While we are pleased to see Medicare rates increasing by more than four percent this coming fiscal year, we are extremely disappointed that CMS enhanced its enforcement provisions surrounding civil monetary penalties. Read our full reaction statement.

AHCA has developed a summary of the final rule. Please note that a member log-in is required to view the summary.

Highlights include:

  • The final rule increases SNF PPS rates by 4.2%, or approximately $1.4 billion, beginning October 1, 2024. This is based on the SNF market basket increase of 3.0%, plus a 1.7% market basket forecast error adjustment, and a negative 0.5% productivity adjustment.
  • The above impact figures do not incorporate the SNF Value-Based Purchasing (VBP) reductions for certain SNFs subject to the net reduction in payments under the SNF VBP program; those adjustments are estimated to total $187.7 million in FY 2025. CMS finalized several operational and administrative proposals for the SNF VBP program.
  • CMS also finalized updates to the SNF Quality Reporting Program (QRP), SNF VBP program, SNF PPS Patient-Driven Payment Model ICD-10 Code Mappings, and the SNF PPS wage index.
  • The rule finalizes revisions to regulation surrounding enforcement authority related to Civil Monetary Penalties (CMP) that were outlined in the proposed rule. Under this new policy, State Survey Agencies, along with CMS would have the authority to issue Per Diem and Per Instance CMPs on the same survey, as well as the authority to issue multiple Per Instance CMPs when the same type of noncompliance is identified on more than one day. CMS or the States would also be able to impose CMPs for the number of days of previously cited noncompliance since the last three standard surveys for which a CMP has not yet been imposed.
  • These enforcement updates go into effect October 5, 2024 (60-days after it is published in the Federal Register, scheduled to be published on August 6, 2024). However, CMS will operationalize these requirements beginning March 3, 2025.

Please contact Martin Allen with any questions regarding Medicare rates and regulatory@ahca.org​ for any questions regarding the CMP enforcement provisions.