The final Hospital Outpatient Prospective Payment System (OPPS) rule issued recently by the Centers for Medicare and Medicaid Services (CMS) eliminates a slew of inpatient-only medical procedures, which has worried has some skilled nursing facility (SNF) stakeholders who think the move will reduce admissions to long-term care communities.

CMS said the rule is an opportunity to modernize the healthcare delivery system by removing 285 procedures labeled inpatient-only, or IPO, with many for acute-care surgeries that have traditionally fueled nursing homes admissions for follow-up care. The rule made no provision for skilled nursing coverage for patients opting for outpatient alternatives that don’t include a requisite three-day stay.

Jay Gormley, COO, Advisory, Zimmet Healthcare Services Group, said CMS insisted that more vulnerable patients may not be best-suited for expanded outpatient options and that it would rely on clinicians to decide on a patient-by-patient basis whether a particular procedure would be best performed in an inpatient setting.

Overall, he said the rule should not have a significant impact on SNFs. “I don’t think the volume is going to be all that great. If patients are at the appropriate level of health to have procedures performed on an outpatient basis that means they’re probably not so sick that they need a three-day stay and would not have been admitted to a SNF, regardless,” Gormley said.

The Rundown

Other quick notes:

-          There is no direct impact on SNF Medicare rates or the Patient Driven Payment Model (PDPM) from the rule.

-          The rule does not touch the SNF Prospective Payment System (PPS), SNF (Quality Reporting Program (QRP), or Value-Based Purchasing (VBP) Program, and there are no SNF-specific quality or reporting changes in the outpatient provisions.

There are, however, items to be aware of for SNFs. These include that the ongoing elimination of the IPO list and expansion of the Ambulatory Surgical Center (ASC) Covered Procedures List will continue the slow, steady erosion of specific inpatient-to-SNF pathways, particularly for joints and some cardiac procedures.

“Healthier elective patients are more likely to bypass the classic ‘inpatient stay plus SNF’ trajectory in favor of ASC and home-based recovery, further concentrating SNF case mix in the frailer, more complex population,” Gormley said.

Another point to consider is the reweighting of the hospital star-rating methodology and tighter hospital price transparency rules “may make acute-care partners more defensive around safety metrics, preferred SNF networks, and readmission performance. Hospitals that see their stars at risk will only lean harder into managing downstream post-acute quality,” he said. 

Finally, the rule “continues to sweeten the pot for non-opioid pain management and stabilizes rates for IOP/PHP behavioral health programs. Those changes live upstream, but over time they may modestly improve the clinical environment around shared patients, particularly for pain and mental health, even if the SNF rate sheet never moves,” Gormley said.

See the CMS rule and information at https://tinyurl.com/4rryp2bj.

Questions or comments? Contact Patrick Connole at pconnole@parkplacelive.com.