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CMS Issues Corrections to FY24 SNF PPS Final Rule Impacting Rates

Please review:  Providers should verify with MDS and billing software vendors that updates have been applied before submitting October 2023 claims.

The Centers for Medicare & Medicaid Services (CMS) issued a Correction Notice that applies to the Fiscal Year (FY) 2024 Skilled Nursing Facility Prospective Payment System (SNF PPS) final rule published on August 7. Although the resulting changes represent only pennies per day, the corrections impact nearly all PDPM urban and rural component rate tables and the rural wage index table. 

Additionally, three corrections were made to the FY24 PDPM ICD-10 mappings file. The effective date for these corrections is retroactive to dates of service beginning October 1, 2023. Provider front office and MDS staff should review the changes and confirm with your software vendors that the updates have been applied prior to submitting Medicare Part A claims, or other payer claims using PDPM payment methodologies, for dates of service on or after October 1, 2023.
 
Wage Index and Rate Corrections Background
CMS has identified a technical error in the calculation of the final FY24 SNF PPS wage indexes resulting from a cost report calculation of one rural hospital in North Carolina and requiring the Agency to recalculate multiple updated tables posted in the Correction Notice to maintain budget neutrality requirements. 
  • Page 68488: The unadjusted SNF PPS Federal per diem rates provided on page 53209 in Tables 3 and 4 of the Final Rule; 
  • Pages 68488 and 68489: The case-mix adjusted SNF PPS rates provided on pages 53210 through 53211 in Tables 5 and 6 of the Final Rule; 
  • Pages 68489 and 68490: The rate computation examples in Tables 8, 9 and 10 on pages 53215 through 53216 of the Final Rule; and 
  • Pages 68490 and 68491: The impact analysis provided in Table 30 on pages 53333 through 53334 of the Final Rule.
 
PDPM ICD-10 Mappings Corrections Background
CMS corrected the following three errors in the FY 2024 PDPM ICD–10 code mappings file that are effective for dates of service on or after October 1, 2023: 
  1. CMS corrected errors in the clinical category assignment of 332 codes ranging from C00.0 through C49.6 to reinstate the prior year's assignments from the FY23 SNF PPS final rule, as the Agency proposed no changes in clinical categories in this code range in the FY24 SNF PPS proposed rule nor finalized them in the FY24 SNF PPS final rule.
  2. CMS is correcting errors in the clinical category assignments of D75.84, F43.81, F43.89, G90.A, and K76.82 to reflect the changes finalized in the FY 2024 SNF PPS final rule (88 FR 53220 through 53221).
  3. The SLP-Comorbidity table in the FY24 PDPM ICD–10 code mappings file displays a list of ICD–10 codes associated with comorbidities included in the Speech-Language Pathology (SLP) component under PDPM. In the Correction Notice CMS notes the removal of the following new ICD–10 codes effective October 1, 2023, that were erroneously added, noting the addition of any ICD–10 code to the SLP comorbidity list would amount to a change in policy that would first need to undergo notice and comment rulemaking: G20.A1, G20.A2, G20.B1, G20.B2, G20.C, G11.6, G23.3, G31.80, G31.86, G37.81, G40.C01, G40.C09, G40.C11, G40.C19, G90.B, G93.42, G93.43, G93.44.
 
Staff Contact: mcarland@mehca.org