There is a freight train loaded with one million more hours of additional administrative burden, increased costs, and staffing pressures for SNFs coming down the tracks in the form of a proposal by the feds to expand the Skilled Nursing Facility Quality Reporting Program (SNF QRP) reporting requirements across all payer types.

If left as is, the proposal starting in Fiscal Year (FY) 2031 would be a seismic change for SNFs, and a negative one at that, experts tell Park Place Live.

Jessie McGill, curriculum development specialist for the American Association of Post-Acute Care Nursing (AAPACN), said the Centers for Medicare and Medicaid Services (CMS) has proposed expanding data collection requirements under the SNF QRP to include all payers for residents admitted or readmitted at a skilled level of care.

“While CMS aims to better align SNF reporting with other post-acute care [PAC] settings, the proposal does not adequately account for the unique structure of the SNF setting and may create unintended consequences that negatively affect data accuracy, comparability, provider burden, and ultimately prioritize paperwork over patients,” she said.

A Heavy Load

One of the most significant concerns with this policy, she said, is the administrative burden it would place on facilities. SNFs would be required to identify and monitor skilled care across all payer types, complete additional assessments at the start and end of skilled care and coordinate ongoing documentation and interdisciplinary review processes that often do not align with existing OBRA assessment schedules and requirements.

Currently, additional documentation and assessments are generally required only for certain payer types, such as Medicare or Medicare Advantage plans, while other payer sources, such as Medicaid, do not require the same level of reporting.

“Under this proposal, facility staff would need to dedicate additional time and resources to determine whether skilled care is being provided at admission or readmission and complete new assessments designed solely to capture SNF QRP data elements,” McGill said.

Although these assessments may sometimes be combined with existing assessments, the greatest burden lies in the ongoing daily monitoring, documentation, and coordination required to determine when skilled care ends and to complete an additional discharge assessment, she added.

$88 Million Bucks

McGill, and another thought leader, said the CMS estimate that the proposal would cost facilities around $88 million annually and require more than one million additional hours each year is too low.

“The estimate appears to account only for completion of the new assessments and MDS items, not the extensive care coordination, daily documentation, and ongoing monitoring required to implement the policy,” she said.

Martin Allen, former senior vice president of reimbursement policy at the American Health Care Association/National Center for Assisted Living, said CMS’s estimates of $88 million annually “seems low on the surface.”

Some History

He said the proposed expansion of nursing home quality reporting measures to all payer types rather than Medicare A residents point out the differences in how the MDS is completed and used.

“Historically nursing facilities have had to manage the assessment calendar for OBRA assessments [for all residents] and PPS assessments [for Medicare A, and more recently Medicare Advantage,]” Allen said.

Nursing homes have had to adapt to modifications to the MDS since inception, he noted.

“Like any CMS issuance the timeline for change is most important. The fact that the implementation will not occur until FY 2031 gives time for providers and their trade associations to have an opportunity for dialogue with CMS on the impact of resident and staffing levels,” Allen said.

Bottom Line

The fact is, he continued, there is no surprise that providers say that the time needed to complete additional paperwork will reduce nursing time spent on patient care.

“No provider is going to voluntarily add staff to meet these requirements. They are going to try to do it with who they have in place. The ability to hire and retain quality nursing staff, especially RNs is limited and costly,” Allen said.

For McGill, there are still many questions remaining on how the proposal would be operationalized, and the broader impact it could have on SNFs.

“AAPACN raised many of these concerns in its formal comments to CMS, including challenges related to Medicare Advantage coverage decisions, workforce shortages, funding, and the potential impact on measure accuracy and validity,” she said.

AAPACN, McGill said, encouraged CMS to consider a phased implementation approach, stronger alignment with other PAC settings, and additional evaluation of operational feasibility to help ensure any quality reporting changes are meaningful, sustainable, and focused on supporting resident care rather than increasing unnecessary administrative burden.

Comments on the CMS proposal are due June 1.

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