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Advocating for Change: ICD-10 Mapping, Office of Management and Budget (OMB) Decreases, and COVID-19

By Jessie McGill, RN, RAC-MT, RAC-MTA - June 16, 2020

Rulemaking is the result of an extensive process. First, CMS proposes a change and allows for a comment period. After reviewing the submitted comments, CMS publishes the final rule. As a professional association, the American Association of Post-Acute Nursing (AAPACN) represents our members through collaboration and advocacy during this process. AAPACN, with expert panel members from both subsidiary associations—the American Association of Directors of Nursing Services (AADNS) and the American Association of Nurse Assessment Coordination (AANAC)—contributed comments to CMS on behalf of our members. The SNF PPS Proposed Rule for FY 2021 was released early this spring and comments were submitted by the June 9 deadline. Here is an overview of the topics in the proposed rule and AAPACN’s collaborative response:  


The proposed rule covers the following areas:

  • Proposed SNF PPS Rate Setting Methodology and FY 2021 Updates

  • Consolidated Billing

  • Revisions to Regulation Text

  • Other Issues: Office of Management and Budget (OMB) Delineations

  • Technical Updates to Patient Driven Payment Model (PDPM) ICD-10 Mappings

  • SNF Value-Based Purchasing (SNF VBP)