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The Center for Medicare Advocacy’s comments on the Medicare prospective payment system for skilled nursing facilities (SNFs),[1] submitted June 20, 2016, support the recommendation of the Medicare Payment Advisory Commission (MedPAC) not to increase reimbursement to SNFs for FY 2017.  MedPAC reports that SNFs have enjoyed Medicare margins exceeding 10% for 15 consecutive years.

With respect to the SNF Value-Based Purchasing Program, the Center expresses concern about the program’s single measure, reducing avoidable rehospitalizations of residents.  Financial incentives not to hospitalize residents may prevent the hospitalization of residents who need hospital care.  Moreover, since studies demonstrate that improving nurse staffing levels would reduce hospitalizations, such enhanced staffing would be a better way of appropriately reducing rehospitalization.

The Center supports the Centers for Medicare & Medicaid Services’ determination not to use sociodemographic status in the SNF Quality Reporting Program, but is concerned about the IMPACT Act-mandated measure of Medicare spending per beneficiary.

The Center’s comments are available at:

[1] CMS-1655-P, 81 Fed. Reg. 24229 (April 25, 2016).


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