Medical Rehab

0 33

On November 15, 2018, the Centers for Medicare and Medicaid Services (CMS) held a National Provider Call for inpatient rehabilitation facilities (IRFs) that focused on the changes included in the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule.

CMS has posted the presentation from this call and recently posted both the audio recording and transcript. RCPA encourages all members in the Rehabilitation Services Division to listen to this recording or read the transcript from this call. Questions can be directed to Melissa Dehoff.

The RCPA staff and conference committee would like to thank you all for sponsoring, exhibiting, advertising, and/or attending the 2018 RCPA Annual Conference.

It’s official: The 2019 RCPA Annual Conference will be held September 24–27 at the Hershey Lodge, in Hershey, PA — be sure to mark this landmark event on your calendars!

It is our hope that, as you plan your 2019 events, you will once again consider supporting and attending the conference. Some other key dates to remember:

  • The 2019 Call for Workshop Proposals will be sent out by the end of January.
  • The request for sponsors, exhibitors, and advertisers will be sent out by the end of February.

For any questions about the RCPA Annual Conference, please contact Sarah Eyster, RCPA Conference Coordinator. We wish you all a happy and safe holiday season.

0 115

During the question and answer segment of the Centers for Medicare and Medicaid Services (CMS) National Provider call that focused on the inpatient rehabilitation facility (IRF) payment and coverage policies for the fiscal year 2019 final rule on November 15, 2018, there was a response from CMS on the role of therapy students in providing care to patients in IRF hospitals and units that caused a great deal of confusion. The question related to counting minutes of therapy provided by a therapy student with guidance. The response was that these minutes would not count, regardless of the level of supervision.

Due to the amount of confusion this call has triggered, the therapy professional associations will be working with CMS on this issue and clarification will likely be forthcoming. RCPA will provide this clarification to members once this is received. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

0 67

On Tuesday, November 27, 2018, the RAND Corporation (a contractor for the Centers for Medicare and Medicaid Services), will hold a stakeholder meeting to discuss their results from the Improving Medicare Post-Acute Care Transformation (IMPACT) Act national beta test of candidate standardized patient assessment data elements (SPADEs). They will also discuss areas of support and key concerns raised by stakeholders during prior engagement activities and answer questions from attendees.

The meeting will be held at the RAND offices, 1200 South Hayes St., Arlington, VA 22202-5050, from 12:00 pm to 4:00 pm.

Attendees can register to attend in person or by phone using the links below. The limited number of in-person spaces will be available on a first-come, first-served basis.

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

0 139

The Centers for Medicare and Medicaid Services (CMS) recently announced they will be holding a National Provider Call for inpatient rehabilitation facilities (IRFs) that will focus on the changes included in the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule. The call is scheduled for Thursday, November 15, 2018 from 1:30 pm – 3:00 pm.

As a reminder, some of the key changes contained in this final rule, which will be a part of this discussion, included:

  • Revisions to coverage criteria;
  • Removal of the Functional Independence Measure (FIM) and Associated Function Modifiers from the inpatient rehabilitation facility patient assessment instrument (IRF PAI); and
  • Refinements to the case-mix classification.

Prior to the call, participants are encouraged to review the Medicare Benefit Policy Manual, Chapter 1, Section 110. A question and answer session will follow the presentation; however, attendees may email questions in advance with “November 15 Call” in the subject line. These questions may be addressed during the call or used for other materials following the call.

Registration is required to participate in this call and will close by 12:00 pm on the day of the call or when it is full. RCPA encourages all of its members in the Rehabilitation Services Division to participate in this call to ask questions, share concerns, etc. with CMS.

Questions can be directed to Melissa Dehoff.

0 141

RCPA’s Rehabilitation Services Divisions (Medical Rehabilitation Committee and Outpatient Rehabilitation Committee) will convene their first networking session in November 2018. To prepare for this session, a Survey Monkey was created to obtain member feedback on their preference for the date and topic for discussion. Members are encouraged to respond to the survey by October 2, 2018. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with any questions.

0 249

The Centers for Medicare and Medicaid Services (CMS) has released the updated Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) Measure Calculations and Reporting User’s Manual (Version 3.0). This version of the manual is effective on October 1, 2018. The manual provides detailed information for IRF Patient Assessment Instrument (PAI) based quality measures, including inclusion and exclusion criteria, quality measure definitions, and measure calculation specifications. All of the materials are available on the Downloads section located at the bottom of the IRF Quality Reporting Measures Information web page.

Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with any questions.

0 355

Recently, the Centers for Medicare and Medicaid Services (CMS) posted to the Proposed Recovery Audit Contractor (RAC) Topics web page a proposed complex nationwide review/audit of inpatient rehabilitation facility (IRF) stays, to determine if they met the requirements to be considered reasonable and necessary.

As part of its updated process for initiating RAC audits, CMS now posts proposed topics on its website for public comment for 30 days. Providers can respond to CMS regarding this proposed audit by sending an email.

0 227

RCPA is offering this exciting opportunity, exclusively for its members!

Tuesday, September 11, 2018 – 2:00 pm to 3:00 pm

In this 60-minute educational members-only webinar, hosted by RCPA and led by Wojdak Government Relations, you will learn about the statewide Quality Care Assessment (QCA), a program that annually provides more than $1 billion in Medicaid payments to hospitals and freestanding medical rehabilitation hospitals. This webinar will provide members with a comprehensive understanding of:

  • The background of the assessment and its initial design;
  • The benefits and challenges of the assessment to the industry and to classes of providers;
  • The details of the recent five year reauthorization;
  • The current politics and state agency dynamics around the assessment;
  • The current federal climate related to provider assessments; and
  • The future opportunities for freestanding medical rehabilitation hospitals.

Following this webinar, there will be a Q&A session to further discuss the presentation and share ideas related to Medicaid payments and policy. Members may also submit questions ahead of the webinar. Please register here.

Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with any questions.

0 503

The Centers for Medicare and Medicaid Services (CMS) published the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule in the August 6, 2018 Federal Register.

Removal of the FIM Instrument and Revisions to the IRF PPS Case-Mix Groups
RCPA was discouraged to see that CMS finalized its proposals to enact new case-mix groups (CMGs) based on function data from the Quality Indicators section of the inpatient rehabilitation facility patient assessment instrument (IRF PAI) and remove the Functional Independence Measures (FIM) instrument from the IRF PAI effective October 1, 2019 (FY 2020). On a positive note, CMS will now have two years of data (FY 2017–2018) in its analysis to develop the FY 2020 CMGs rather than using FY 2017 data alone as originally proposed. CMS has indicated that any changes to the revised CMG definitions will be addressed in future rulemaking prior to implementation in FY 2020. In addition, CMS states it plans to provide training and educational resources on the data items in the Quality Indicators section of the IRF PAI before the new policies take effect on October 1, 2019. The final rule does not include additional analytical reports or data beyond what was published in the proposed rule, but members are encouraged to review the technical report that was referred to in the proposed rule (Analyses to Inform the Potential Use of Standardized Patient Assessment Data Elements in the Inpatient Rehabilitation Facility Prospective Payment System by RTI International).

Changes to IRF PPS Coverage Requirements
CMS adopted all of its proposals relating to the IRF coverage requirements, including:

  • Proposal to allow the Post-Admission Physician Evaluation to count towards one of the required three weekly face-to-face physician visits during the first week of a patient’s stay in an IRF.
  • Remote physician attendance and allowance to lead discussion at interdisciplinary team meeting without any additional documentation requirements. CMS notes that hospitals would still be able to set their own policies about remote attendance, and that this proposal would alleviate documentation burden on physicians and allow the physicians “increased flexibility for time management.”
  • Admission order documentation requirement. CMS adopted its proposal to remove the requirement under the IRF PPS regulations that there be a physician order for inpatient care in the medical record. CMS believes this requirement is duplicative of the requirements under the Medicare Conditions of Participation (CoPs) regulations as well as the requirements under the general Medicare Part A payment regulations that are applicable to IRFs. Therefore, even though this requirement is eliminated, there will still need to be an admission order when a patient is admitted to an IRF since IRFs must adhere to all CoPs.
  • Input on additional changes to the physician supervision requirements. CMS requested input on two areas being considered for future changes. The first area is whether some of the three weekly required physician visits could be completed remotely. The second area CMS requested information on was the use of non-physician practitioners, such as physician assistants, to satisfy some of the coverage criteria that must currently be completed only by a physician. CMS did not provide a detailed response to comments submitted, but said it would consider these stakeholder comments for future rulemaking.

Proposed Changes to IRF QRP
CMS adopted its proposals to remove two measures from the IRF quality reporting program (QRP):

  • National Healthcare Safety Network (NHSN) Facility-wide Inpatient Hospital-onset Methicillin-resistant Staphylococcus aureus (MRSA) Bacteremia Outcome Measure (NQF #1716).
    • IRFs will no longer be required to submit data on this measure for the purposes of the IRF QRP beginning with October 1, 2018 admissions and discharges.
  • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680).
    • Providers will no longer be required to submit data on this measure for the purposes of the IRF QRP beginning with patients discharged on or after October 1, 2018. The IRF-PAI data items associated with reporting this measure (O0250A, O0250B, and O0250C) will be removed from the IRF-PAI version 3.0 effective October 1, 2019.
    • Beginning with October 1, 2018 discharges and until IRF-PAI version 3.0 is effective, IRFs should enter a dash (–) for items O0250A, O0250B, and O0250C. CMS states that it will provide ongoing guidance to providers to clarify that use of a dash for these assessment items beginning October 1, 2018 is appropriate and will not cause a non-compliance determination.

CMS finalized its proposals to begin publicly displaying data on the following four assessment-based measures in CY 2020, or as soon thereafter as technically feasible:

  • Change in Self-Care (NQF #2633);
  • Change in Mobility Score (NQF #2634);
  • Discharge Self-Care Score (NQF #2635); and
  • Discharge Mobility Score (NQF #2636).

Changes to the IRF PPS Payment Rates for FY 2019
CMS finalized most of its payment proposals for FY 2019. However, it made small adjustments to the originally proposed outlier threshold and labor-related share due to updated data that had become available since the proposed rule.

RCPA was asked to submit a letter of support from the House Ways and Means Committee; view a copy of that letter here.

These regulations become effective on October 1, 2018. For additional information, CMS has posted a fact sheet. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.