In comments to the Centers for Medicare and Medicaid Services (CMS) on June 25, AHCA emphasized its key concerns with the proposed new Skilled Nursing Facility Prospective Payment System (SNF PPS). The new payment system, called the Patient-Driven Payment Model (PDPM), would replace the Resource Utilization Group (RUGs) PPS entirely on October 1, 2019. According to a message to the membership from AHCA Senior Vice President of Reimbursement Policy, it is as yet unclear if CMS’ proposed implementation date is feasible.  

Movement from RUGs to PDPM would be the most significant change in SNF payment since the late 1990s. AHCA submitted two comment letters, an early letter submitted on May 24 emphasizing key concerns and the formal, detailed comment letter on June 25. Both letters represent extensive member input and guidance on the part of AHCA’s Reimbursement Committee, Clinical Practices Committee, Clinical and Performance Data Management Committee, and the Legal Committee.  

AHCA’s June comment letter is one tactic of the PDPM advocacy strategy. In the coming weeks and months, AHCA will be meeting with a variety of senior CMS officials to emphasize our concerns, proposed solutions, and member priorities. We also will continue valuable collaboration with over 14 sister associations with whom we are working on PDPM advocacy.  

Please contact Mike Cheek with your questions, suggestions or concerns. 

Additional Information

PDPM Could Create New Challenges for Skilled Nursing, AHCA Says (Skilled Nursing News, June 28, 2018)