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CMS took the long-term care profession by surprise in April when the SNF PPS Proposed Rule revealed the Patient-Driven Payment Model (PDPM). With a proposed implementation date of October 1, 2019, PDPM would replace RUG-IV without a phase-in or blended transition. CMS provided a 60-day comment period for the public to express concerns, support, and other feedback on the proposed rule, and AANAC responded. Following weeks of collaboration with our sister organization, AADNS, and with the Expert Advisory Panel members from both organizations, members, and other stakeholder groups, AANAC and AADNS jointly submitted 25 pages of comments to CMS. (For purposes of brevity in this article, the issuer of those comments is referred to as AANAC, but the collaborative effort should be understood.)
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