The only thing easy to understand about the new Skilled Nursing Facility Value-Based Purchasing (SNF VBP) program is how complex it is.
The Centers for Medicare & Medicaid Services (CMS) is trying to clarify the complicated initiative by providing new information and resources for providers. In its first communication outreach effort regarding SNF VBP, CMS held an open conference call through its Medicare Learning Network to review program specifics and unveil new sources of information for providers.
Under the SNF VBP program, claims for services furnished on or after Oct. 1, 2018, will be subject to a 2 percent withhold. Providers will have the opportunity to get some or all of this money back depending on how well they do in managing hospital readmissions and meeting or exceeding performance standards.
Top-performing providers could conceivably get back more than the 2 percent they had withheld, although CMS says that specifics about how much more than 2 percent the incentive will be and how many will get it is still being determined.
SNFs will be rated on achievement against all other facilities nationally as well as on their own improvement, comparing their rate during 2017 with their previous performance during 2015.
The key metric for the program is known as the SNF 30-Day All-Cause Readmission Measure (SNFRM). SNFRM estimates a risk-standardized rate of all-cause, unplanned hospital readmissions of Medicare SNF beneficiaries within 30 days of discharge from their prior acute hospitalization.
Under the program, hospital readmissions are identified through Medicare claims. Readmissions within the 30-day window are counted regardless of whether the beneficiary is readmitted directly from the SNF or from home following discharge from the SNF.
Rates will be risk-adjusted based on patient demographics, principal diagnosis in prior hospitalization, comorbidities, and other health status variables that affect the probability of readmission.
The program excludes planned readmissions since these are not considered preventable. Also excluded are the following:
Â·Â Â Â Â Â Â Â Â Patients who were hospitalized for medical treatment of cancer.
Â·Â Â Â Â Â Â Â Â Patients who do not have Medicare Part A coverage for the full 30-day window and those who do not have Part A coverage for the 12 months preceding the prior hospital discharge.
Â·Â Â Â Â Â Â Â Â SNF stays with an intervening post-acute care admission within the 30-day window.
Â·Â Â Â Â Â Â Â Â SNF stays with more than one day between the hospital discharge and the SNF admission.
Â·Â Â Â Â Â Â Â Â Patient discharge from the SNF against medical advice.
Â·Â Â Â Â Â Â Â Â Principal diagnosis in prior hospitalization was for rehabilitation, fitting of prosthetics, or adjustment of devices.
Â·Â Â Â Â Â Â Â Â Prior hospitalization for pregnancy.
CMS says that in subsequent years, a new metric will be used: SNF Potentially Preventable Readmissions (SNFPPR). This measure follows the same logic as the SNFRM but only counts a smaller subset of readmissions that are considered potentially preventable.
CMS will issue quarterly confidential feedback reports to SNFs on their performance on the measures specified for the SNF VBP program. CMS is currently developing these reports, as well as operational systems and implementation guidance.
CMS says it intends to provide the reports via the Quality Improvement and Evaluation System Certification and Survey Provider Enhanced Reports (CASPER) files currently used by SNFs to report quality performance.
Reports will include facility-specific SNFRM data calculated during the period as well as national average rates calculated from claims paid during the period.