New resource: AHCA has developed a member summary (log-in required) of the CMS final rule for the skilled nursing facility (SNF) prospective payment system (PPS) fiscal year (FY) 2025.

What’s in the rule: The final rule increases Medicare rates by more than four percent for the coming fiscal year. It also revises CMS’s enforcement provisions for civil monetary penalties (CMP), effective October 5, 2024. However, CMS will operationalize these requirements beginning March 3, 2025. 

Highlights of the final rule include:

• The final rule increases SNF PPS rates by 4.2 percent, or approximately $1.4 billion, beginning October 1, 2024. This is based on the SNF market basket increase of 3.0 percent, plus a 1.7 percent market basket forecast error adjustment, and a negative 0.5 percent 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.

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