LeadingAge CMS-1834-P Comments: 3-Day Stay Must End to Preserve Access to SNF

In comments to the Centers for Medicare and Medicaid Services (CMS) on the hospital outpatient prospective payment rule (CMS-1834-P) related to a proposal that would completely phase out the procedures on the Inpatient Only List over the next three years, LeadingAge highlighted that this shift could remove access to skilled nursing facility (SNF) services that have often followed many of these procedures-and especially the musculoskeletal procedures proposed for elimination in 2026.

Submitted September 15, our comments explain that without a 3-day inpatient hospital stay, Medicare fee-for service (FFS) beneficiaries would no longer be able to receive skilled care or rehabilitative therapies in a SNF, and have those services paid by Medicare.

LeadingAge members reported that roughly 20-50% of their admissions currently are for musculoskeletal procedures that would be impacted by the rule change. Therefore, we proposed CMS pursue eliminating the 3-day stay requirement and in the interim, exempt any procedures removed from the Inpatient Only List from requiring a 3-day hospital stay in order to preserve access to SNF services post-procedure.

We also encouraged CMS to reimagine how SNFs could play a key role in reducing Medicare costs for individuals with chronic conditions that need additional short-term support to manage their condition.

Our full comment letter can be found here.