The Centers for Medicare & Medicaid Services (CMS) issued its Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule for FY 2012 this afternoon. The American Health Care Association (AHCA) is conducting an in-depth analysis of the final rule, but AHCA's initial review shows cause for concern and extreme disappointment. The rule ignores a unified message from members, caregivers, lawmakers and stakeholders to find a responsible solution to Medicare payments.
Similar to what was first proposed by CMS in late April, the agency will cut Medicare payments by 11.1 percent starting October 1, totaling $3.87 billion. As you know, these reductions are an attempt to return the Medicare system back to budget neutrality for CMS after implementing RUG-IV and MDS 3.0.
CMS also implemented modifications to group therapy and to Change of Therapy (COT) and End of Therapy (EOT) Other Medicare Required Assessments (OMRAs), virtually without any modification from the proposed rule.
Unfortunately, CMS has disregarded AHCA's sound and reasonable approach to implement modest reductions to SNF payments over multiple years. AHCA's proposal would have protected long term care for seniors, while also achieving the government's goal of a budget-neutral payment system. CMS' action also failed to acknowledge the tens of thousands of letters, emails, and phone calls all of you made to let the agency know how damaging such a drastic proposal would be to the profession and the economy.
These are only the initial findings, and the AHCA team is combing through the 300 plus page final rule. But AHCA have already issued a strongly-worded statement demonstrating its disappointment with CMS for issuing such irresponsible public policy. In the coming days, AHCA will provide an overview and let you know what this means for the Association and the profession. But one thing is certain - AHCA will continue to work with CMS and lawmakers on Capitol Hill to implement regulations and policies that are fair to all involved.
Please keep watch for more detailed information very soon. If you have any questions, please contact Elise Smith, esmith@ahca.org, or Bill Hartung, whartung@ahca.org.
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