The Centers for Medicare & Medicaid Services (CMS) contractor Acumen LLC hosted a listening session on August 29 to solicit feedback on potentially expanding the pool of data from which skilled nursing facility (SNF) Quality Reporting Program (QRP) data is collected. The expansion would mean collecting data for SNF QRP on all residents receiving skilled services regardless of payer type, as opposed to the current policy of collecting data only for skilled services covered under Medicare Part A Fee-for-Service. For those who missed the listening session or who wish to provide additional feedback, Acumen will accept written comments until September 28, 2023, by email (SNF-Listening-Session-2023@acumenllc.com) on the following topics:

• Defining the population: Using the definition of skilled services outlined in Chapter 8, Section 30.2 of the Medicare Benefit Policy Manual, would it be feasible to identify residents requiring an MDS assessment for purposes of the SNF QRP? If not, what problems would you encounter? How do plans other than Medicare “skilled services”? Are there other considerations to be aware of?
• Identifying the population: Would adding an item to the MDS such as that used for LTCH assessments for beneficial for providing information on the resident’s source of payment for services received in the SNF? Who is primarily responsible for filling out this information on the MDS? Do you have any suggestions for how CMS could ensure the payment information collected is accurate? Are there other considerations for changes to the MDS that would be necessary to accommodate an all-payer proposal?
• MDS burden for all-payer proposal: What percentage of your total stays do you estimate combine the 5-day and comprehensive assessments? What percentage of your non-Medicare FFS residents admitted for skilled services of <14 days are you already completing a five-day assessment for? Do other payers require portions of the MDS to be filled out for them regardless of the length of the resident’s stay? Do other payers have an assessment tool other than the MDS that they require you to complete when residents are admitted for services?
• Changes in levels of care: What kinds of changes in service level should an all-payer policy consider? Would there be benefits of having payer source and quality data reported on all your residents when changes in the level of care happen within your SNF?