FY 2025 SNF PPS Final Rule

August 1, 2024-- On July 31, 2024, CMS issued the FY 2025 SNF PPS Final Rule for the fiscal year 2025, which begins on October 1, 2024, and ends on September 30, 2025. The final rule, for the most part, reflects consistent language from the proposed rule, including payment rate updates, expanded nursing home enforcement penalties, revised ICD-10 code mappings, and verbiage outlining several future initiatives and changes. The Final Rule will be published on August 6, 2024.

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Payment Rate Increase

The rate update results in a net increase of 4.2%, representing about 1.4 billion dollars in Medicare Part A payments for 2025. It is the highest in recent years and breaks down as follows:

Industry concerns continue related to the Final Minimum Staffing Rule for Nursing Homes. The 4.2% increase would not come close to covering the increased staffing mandate costs. 

Additionally, the payment increase does not include the 2% withhold for the Value-Based Purchasing Program, which reduces payments by $196.5 million. With 54 counties moving from rural to urban and 54 counties moving from urban to rural, the estimated overall impact would be 43% of SNFs seeing a decrease and  57% of SNFs seeing an increase.

Code Mapping Changes

Four changes to ICD-10 clinical mappings have been finalized, changing the clinical category assignment from Medical Management to the clinical category of Return to Provider for the following ICD-10 codes:

• E88.10 Metabolic Syndrome
• E88.811 Insulin Resistance Syndrome, Type A
• E88.818 Other Insulin Resistance
• E88.819 Insulin Resistance, Unspecified

CMS believes treatment for these conditions typically occurs outside of a Part A SNF stay.

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Expanded Penalties

The final rule also expands penalties that can be imposed through regulatory revision to allow for more per instance and per day Civil Monetary Penalties, specifically:

This expands CMS’ authority to impose multiple PI CMPs when the same type of noncompliance is identified on more than one day regardless of whether or not the deficiencies constitute immediate jeopardy.. CMS’ current enforcement regulation does not allow for PI and PD CMPs to be imposed for the same survey.  

These requirements will be operationalized beginning March 3, 2025. This will allow CMS to make the corresponding changes in their system while transitioning to a new technology platform (iQIES) and provide the necessary training to implement these changes. 

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QRP Changes

The Final Rule adds four fields to the social determinants of health (SDOH) category that would be incorporated into a newly added Section R, Health-Related Social Needs for FY 2027 SNF QRP. The new questions are: 

• Living Situation - “What is your living situation today?” 
• Food – Two questions, with the same list of response options: “Within the past 12 months, you worried that your food would run out before you got money to buy more,” and, “Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more.”
• Utilities – “In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?” 

CMS will modify the current transportation question to align it with the question in other programs: 

• Transportation – “In the past 12 months, has a lack of reliable transportation kept you from medical appointments, meetings, work, or from getting things needed for daily living?” 

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RFI for Potential QMs and Updates to NTA

CMS thanked commenters for providing requested information for several potential changes in upcoming years, including those to NTAs and a data validation process for QRP. CMS states that they will consider the feedback for future development. CMS also acknowledged specific feedback related to the validity of data and comorbidities that advocacy groups, including Powerback Rehabilitation, commented on.

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Click here for the full Final Rule.

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