Detangling the SNF PPS: Why More Data May Trump More $

On a scale of 1 to 10, where 10 represents extreme anticipation for the SNF PPS Final Rule, FY 2027 was tracking at about a 3 for me. I got what I expected.

Also as expected, I’m not aligned with the industry’s reaction. I’m an advocate for Skilled Nursing, not a shill or a lobbyist. Any discussion of Medicare increases failing to keep pace with rising expenses is largely posturing and arguably counterproductive.

The 2.4 percent update nets roughly $57,000 per SNF if averaged. Would I rather see more money? Absolutely. Would an average of $570,000 be better? Absolutely not. National averages are meaningless when Medicare days fall below 6 percent at 5,000+ providers while the top 500 average 50 percent.

Medicare revenue cannot save the patient day anymore. Even I’ve quit complaining about it. That’s a lie. I’m trying to quit or trying to try at least.

More Data Can’t Be Bad

And while I have an ocean’s worth of issues with the context and construction of traditional analytics, I applaud CMS’s continuing efforts to gather broader, more timely data. That is precisely why the data expansion may matter more than the payment update. Distorted data obscures the operating realities CMS is finally trying to measure.

The finalized requirement for SNFs to submit MDS data for residents admitted or readmitted for covered skilled care, regardless of payer, was awkwardly worded and caused confusion. I thought I was missing something, so I called our reimbursement and compliance expert Alicia Cantinieri, who put the rule in perspective:

“It’s not like we’re going back to therapy OMRAs and assessment-date gymnastics to combine the 90-day assessment with the quarterly.” Those words gave me chills.

CMS is creating an Other Skilled Care Admission Assessment and an Other Skilled Care Discharge Assessment for covered non-FFS stays. Wow, that’s a mouthful.

In any event, this data will highlight rate compression and distress that Medicare Advantage (MA) causes providers. Which reminds me, I didn’t get the chance to address the snow job MedPAC published in their June Report to Congress that said MA does not distress providers. MedPAC should now look at what it’s costing states to backfill those losses for proof.

Back to SNF PPS. The long-term assessment schedule does not change, and residents who become skilled in place do not trigger an SCA or SCD. But if it did change, the SCA could have a bright side in most states. The next time Medicaid scolds an operator for shifting assessment dates solely to optimize CMI, the provider could reply, “But Medicare made me do it!”

Same as it Ever Was

On the other hand, we may have I-SNP drama. That’s a nuanced story for another time, and we’ve got a few years. The unfortunate lesson here isn’t about what changes, it’s about what doesn’t.

Apart from the administrative presumption of coverage, limited three-day-rule waivers, and temporary PHE flexibilities, Core Medicare SNF benefit-eligibility rules are essentially the same ones restored after the 1988 Catastrophic Coverage Catastrophe was repealed the next year.

My old transparency-projector slides from the ’90s are still spot-on. In fact, I’m thinking of going old school for The Reimbursement Symphony. We could all use a break from technology for a few days.

Marc Zimmet is the CEO of Zimmet Healthcare Services Group.