The FY 2023 SNF PPS Final Rule introduced regulatory and reimbursement changes for SNFs, including influenza vaccination reporting requirements. As an industry we are continuing to see expansions to CMS Quality Initiatives like the SNF Quality Reporting Program as well as the SNF Value Based Purchasing Program. Providers should be prepared for this current Influenza Vaccination season so our experts at Engage Consulting have outlined the important reporting requirements, deadlines, and potential reimbursement reductions if guidelines aren’t met.
Below is the summary of what SNF leaders need to know to not be caught off guard with these new changes that went into effect 10/1/22.
FY 2024 SNF QRP: Influenza Vaccination Coverage among Healthcare Personnel (HCP)
Even though this new SNF QRP measure goes into effect for FY 2024, the reporting of the required information starts now for the 2022-2023 flu season. SNFs are required to report annual HCP influenza vaccination summary data through the NHSN Healthcare Personnel Safety (HPS) Component for the 2022-2023 influenza season. The CDC and NHSN have recently released a training summary that can be found here.
SNFs will be required to submit one report covering the entire influenza season by the established deadline of May 15, 2023. Reporting is required for any full-time or part-time healthcare employee that was physically present in the facility for at least one working day between October 1, 2022 through March 31, 2023. The required reporting categories include the following:
Facility employees (staff on facility payroll)
Non-Employee- Licensed Independent Practitioners (physicians, APN, PA) not employed by facility
Non-Employee- Adult Students/Trainees and Volunteers
NHSN will not require reporting of “other contract personnel” who provide care, treatment or services at the facility through a contract (such as contract therapy or food nutrition providers). It is optional reporting for “other contract personnel”. The instructions require that a SNF will report the total number of HCP for each of the categories below:
Facilities cannot afford to miss the required reporting deadline or provide incomplete information. Facilities failing to report 100% of the data for measures submitted through the NHSN, are subject to a 2% reduction in annual payment update (APU). Effective for FY 2023 APU, providers are required to meet the following requirements:
80% of MDS assessments have 100% of the required data, and
100% of data for measures submitted using the CDC NHSN (including COVID-19 Vaccine Measure and HCP Influenza Vaccine Measure)
It is imperative that facilities are prepared to collect the required data for the 2022-2023 Influenza Vaccination season and meet the reporting deadline of May 15, 2023. To learn more about these changes as a result of the FY 2023 SNF PPS Final Rule, watch this 30-minute video here. If you would like to learn more about specialized consulting services, you can contact Jennifer Napier, Director of Clinical Consulting at Jennifern@engageconsultingpartners.com.