Dear CMS: Our questions regarding PDPM

On May 8, CMS issued the Fiscal Year 2019 SNF Proposed Rule. Since then, Consonus Leadership has been reviewing, pondering and ultimately questioning the Proposed Rule’s content. Comments were due back to CMS by June 30.

Here are the key questions providers and stakeholder groups like Consonus are communicating to CMS in response, to ensure continued success for the people we serve:

Dear CMS,

1. How can we guarantee cost data you used as the basis for PDPM is continuously updated?

Much of the data used to establish the cost information for PDPM comes from a study that involved a small number of volunteer SNFs.  Some of the data, like that from Section GG, has never been made public or shown to be reliable or valid.  Will CMS continue to evaluate and update the system as more reliable data is collected?

2. What are the implications of moving away from a volume-based system to a patient driven system?

A few follow-up questions to this: What exactly is the relationship between patient care and payment?  Is there an expectation to provide services just because they are included as a component for payment?

There are many changes associated with this shift. PDPM relies on beneficiary placement into one of only 10 clinical categories derived from thousands of possible ICD-10 codes.  Since SNFs do not employ professional coders or have access to hospital selected ICD-10 coding in a timely manner, a case could be made for SNFs to use a checkbox to select one of the ten clinical categories that represent the reason for the SNF stay, creating an easier, more streamlined process.

In addition, CMS’s definition for Group Therapy in the SNF setting does not match the definition of the Group CPT code, nor the definition of Group Therapy in the IRF setting.  Concurrent is also a definition created by CMS in response to a volume based system.  The 25% limit was selected without supporting evidence.  If the industry is moving to a patient driven system, the clinician should determine the type and amount of treatment the patient needs.

Despite concerns, payment reform is vitally necessary and providers welcome the change to a system driven more by patient need than the volume of specific services.  Sorting out the details will be the challenge but there is hope of achieving better care and better outcomes to those we serve.

3. What will a PDPM implementation plan look like for providers?

We know that change takes time.  Providers are asking CMS to provide the necessary lead-time to implement PDPM.  Just from an IT perspective, it takes 9-12 months from the release of technical specifications to program, test, train, and implement changes. Many providers would like to see pilot programs and testing occur prior to a full implementation.


Despite lingering questions like these, here’s what we DO know: Consonus is ready. Take a look at how we have prepared for the inevitable shift, here.