AHA Comment Letter on CMS’ Skilled Nursing Facility Proposed Payment Rule FY 2025

May 24, 2024

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1802-P, P.O. Box 8016
7500 Security Boulevard
Baltimore, MD 21244–1850

Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2025; 89 Fed. Reg. 23,234 (April 3, 2024).

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 500 skilled-nursing facilities (SNFs), and our clinician partners — more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2025 SNF prospective payment system (PPS) proposed rule.

SNFs play a critical role in the continuum of care, particularly for many hospitalized patients. For example, as AHA highlighted in last year’s rulemaking, hospitals have faced increasing difficulty discharging patients to post-acute care, including SNFs. This challenge has largely been due to staffing shortages and associated reduced capacity of SNFs and other providers. These shortfalls then place additional burden back on hospitals, including the need for hospitals to board patients until a discharge location can be found. Therefore, it is vital for the entire continuum of care that SNFs are properly resourced.

As such, AHA is concerned that CMS’ payment updates, in addition to increased requirements on SNFs, will exacerbate their, as well as hospitals’, financial difficulties. Therefore, we request that CMS more closely examine its process for forecasting and providing market basket updates. This is especially true for hospital-based SNFs, which care for a distinct patient population that is more resource-intensive.

View the detailed letter below.