Alliance Comments on CMS Proposed Rule Offers 'Measured, Responsible and Reasonable' Approach to Fine-Tuning Medicare Payment System to U.S. Skilled Nursing Facilities (SNFs)
Protecting Quality Care for Seniors, Preserving Workers' Jobs, Ensuring Accountability to U.S. Taxpayers Key Objectives of Proposal
WASHINGTON, June 28, 2011 /PRNewswire-USNewswire/ -- In offering comments to the Centers for Medicare and Medicaid Services (CMS) on the Notice of Proposed Rulemaking on the Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2012, the Alliance for Quality Nursing Home Care characterized its proposed approach to fine-tuning the Medicare payment system used to reimburse America's SNFs as "Measured, Responsible and Reasonable."
"Our objective is an accurately calibrated payment system under Medicare that proceeds to fine tune our Medicare payment system in a manner that assures seniors are protected, SNF economics are sustainable, local jobs are preserved, and accountability to taxpayers is achieved," stated Alan G. Rosenbloom, President of the Alliance. "The proposal we offer is a measured, responsible and reasonable approach to achieve these critical health policy objectives."
Rosenbloom said it is critical to address this issue in the context of other fundamental issues affecting SNFs, and pointed to key factors such as rising patient acuity, shrinking length of stay, escalating costs, and plummeting state Medicaid funding as an important context for decision-making on Medicare funding issues. "These are vital variables meriting consideration as the process towards a final rule ensues," he said.
The Alliance Proposal
To ensure Medicare prospectively pays appropriately under the new RUGs-IV system, the Alliance proposes that CMS immediately implement a 3% payment reduction beginning in FY 2012. After this reduction is taken, the Alliance proposes that CMS continue to evaluate and adjust payment rates every six months based on additional data and experience with the new system.
Under this plan, payment rates would be adjusted every six months in FY 2012 and FY 2013, until the RUGs-IV payment system is corrected. As part of this effort, if proposed changes to group therapy and reporting changes are not deferred, any payment reductions resulting from these new requirements would be taken into account in determining whether budget neutrality was reached.
At the end of FY 2013, CMS would make any further adjustments needed to complete the process of returning the SNF payment system to budget neutral. This means that any excess payments that occur in FY 2012 or FY 2013 as the RUG-IV system recalibration is being implemented will be returned to the Medicare program by the end of FY 2013.
"This measured, responsible and reasonable approach would result in the RUGs-IV payment system being fully corrected by the end of FY 2013," Rosenbloom said. "The approach also ensures that payment corrections do not disrupt nursing homes' ability to continue offering quality care to Medicare patients across the nation – which must never be disrupted."
For Full Text of Alliance release and more context to CMS comments, please go to www.aqnhc.org.
SOURCE Alliance for Quality Nursing Home Care
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