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Medical Rehab

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The Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the inpatient rehabilitation facility prospective payment system (IRF PPS) for fiscal year (FY) 2020.

Some of the key proposals in the rule include:

  • Net Payments: Net payments for IRF’s would increase by 2.3 percent, including a 3.0 percent market basket update, offset by a statutorily mandated cut of 0.5 percentage points for productivity, and a 0.2 percent decrease in outlier payments. This update reflects the proposed revision and rebasing of the market basket using data from 2016 as the base year instead of 2012.
  • Case-Mix Revisions: The Functional Independence Measure (FIM) and Functional Modifier items were removed from the IRF Patient Assessment Instrument (PAI) as finalized in the FY 2019 IRF PPS final rule. CMS also indicated that the FY 2020 case-mix groups (CMGs) would be based on a patient’s motor function, age, memory function, and communication function. However, in this proposed rule CMS made the decision not to include the communication and memory scores because their inclusion in the CMG definitions resulted in lower payments for patients with cognitive deficits (based on their analysis of two years of data).
  • Outlier Threshold and Cost-to-Charge Ratio: CMS proposes to update the outlier threshold amount from $9,402 for FY 2019 to $9,935 for FY 2020 to ensure outlier payments account for 3 percent of total payments, as they did for FY 2019. CMS notes that its initial analysis showed that outlier payments would be 3.2 percent and made the above proposed adjustment to maintain it at 3 percent.
  • Rehabilitation Physician Definition: CMS proposes to clarify that compliance with the regulatory definition of “rehabilitation physician” (a licensed physician with specialized training and experience in inpatient rehabilitation) will be determined by the IRF. Currently, the regulations do not specify the level or type of training or experience that are required to satisfy this criteria.
  • Proposed Changes to IRF Quality Reporting Program (QRP): CMS proposes to adopt two measures to the IRF QRP with data collection for discharges beginning October 1, 2020.
  • Transfer of Health Information to the Provider
  • Transfer of Health Information to the Patient

Transfer of Health Information is a required domain of the IMPACT Act and CMS has been developing these measures since 2016. The measures are process-based measures that assess if a “current reconciled medication list” is given to either the subsequent provider or to the patient/family/caregiver when the patient is discharged or transferred from his or her current PAC setting. CMS proposes to start collecting the measure via the IRF-PAI for discharges beginning October 1, 2020.

  • Proposed Revision to Discharge to Community Measure: CMS proposes to revise the Discharge to Community post-acute care measure to exclude baseline nursing facility (NF) residents from the measures beginning with the FY 2020 IRF QRP due to stakeholder recommendations.

CMS proposes to define baseline NF residents as those who had a long-term NF stay in the 180 days preceding their hospitalization and IRF stay.

  • Proposed Standard Patient Assessment Data Elements (SPADEs): This proposal is slated for reporting beginning in October 2020. In line with the IMPACT Act, CMS is required to develop and collect standardized patient assessment data in PAC settings. In this rule, CMS proposes to adopt ”many of” the standardized patient assessment data elements (SPADEs) it had previously proposed in the FY 2018 IRF PPS proposed rule, as well adopt new SPADEs on social determinants of health. Some proposed items, such as the Brief Interview of Mental Status (BIMS), are currently on the IRF-PAI, in which case CMS is proposing to formally adopt them as SPADEs. However, most of the proposed items would entail adding new, additional reporting elements to the IRF-PAI.
  • Proposal to Collect All-Payer IRF PAI Data: CMS proposes to expand the reporting of the IRF-PAI data to include data on all patients, regardless of their payer, beginning with patients discharged on or after October 1, 2020.

The proposed rule will be published in the April 24, 2019 edition of the Federal Register. Comments on the provisions contained in the proposed rule will be accepted until June 17, 2019. Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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2019 marks the official 18th anniversary of Sexual Assault Awareness Month (SAAM) — but did you know we can trace its history even further back?

Even before its official declaration, SAAM was about both awareness and prevention of sexual assault, harassment, and abuse. Looking at the history of the movement to end sexual violence, it’s clear why: it’s impossible to prevent an issue no one knows about, and it’s difficult to make people aware of a problem without providing a solution. The two work in tandem, and they always have. From the civil rights movement to the founding of the first rape crisis centers to national legislation and beyond, the roots of SAAM run deep.

Roots of the Movement
As long as there have been people who care about making the world a better place, there have been individuals advocating for sexual assault prevention. In the United States, movements for social change and equality began to gain traction in the 1940s and 50s with the civil rights era. Although open discussion of the realities of sexual assault and domestic violence were limited at these times, activists for equal rights began to challenge the status quo.

Sexual Assault Awareness Month is about more than awareness — the ultimate goal is prevention. Since consent is a clear, concrete example of what it takes to end sexual harassment, abuse, and assault, this year’s theme centers on empowering all of us to put consent into practice. The campaign theme, I Ask, champions the message that asking for consent is a healthy, normal, and necessary part of everyday interactions.

Sexual assault is a serious and widespread problem. Nearly one in five women in the US have experienced rape or attempted rape at some time in their lives, and one in 67 American men have experienced rape or attempted rape. When we talk about prevention, we mean stopping sexual violence before it even has a chance to happen. This means changing the social norms that allow it to exist in the first place, from individual attitudes, values, and behaviors to laws, institutions, and widespread social norms. Prevention is everyone’s responsibility: All of us can create and promote safe environments. We can intervene to stop concerning behavior, promote and model healthy attitudes and relationships, and believe survivors and assist them in finding resources.

The National Sexual Violence Resource Center (NSVRC) is the leading nonprofit in providing information and tools to prevent and respond to sexual violence. NSVRC translates research and trends into best practices that help individuals, communities, and service providers achieve real and lasting change. The center also works with the media to promote informed reporting. Every April, NSVRC leads Sexual Assault Awareness Month (SAAM), a campaign to educate and engage the public in addressing this widespread issue.

Be sure to share your sexual assault awareness programs and activities on social media, and feel free to share on the RCPA Facebook page and Twitter feed as well.

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One of the topics on the agenda at the March 2019 Medicare Payment Advisory Commission (MedPAC) public meeting focused on the evaluation of an episode-based payment system for post-acute care (PAC). MedPAC advises Congress about the federal programs (Medicare and Medicaid). Over the years, there have been many discussions regarding whether the federal government should implement one payment system across post-acute providers, which vary greatly in how they are paid. Post-acute providers include inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs), home health agencies, and long-term care hospitals (LTCHs). During the March presentation, MedPAC shared that they favor a stay-based system, rather than one tied to a whole episode of care for fear that the episode of care would encourage providers to discharge patients early. The Department of Health and Human Services (HHS) will work with an outside vendor to build a unified PAC payment model with a goal to submit it to Congress by 2022. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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The Centers for Medicare and Medicaid Services (CMS) recently updated the inpatient rehabilitation facility (IRF) provider preview reports. The data contained in these reports is based on quality data that was submitted by providers between Quarter 3 for 2017 and Quarter 2 for 2018 and reflects what will be published on IRF Compare when the site is refreshed in June 2019. Instructions are available for providers on how to review the reports. The reports will be available for providers to review until April 3, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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The Department of Defense (DoD) issued a proposed rule to add certified or licensed physical therapy assistants (PTAs) and occupational therapy assistants (OTAs) as TRICARE-authorized providers, to engage in physical or occupational therapy, under the supervision of a TRICARE-authorized physical or occupational therapist, in accordance with Medicare’s rules for supervision and qualification when billed by under the supervising therapist’s national provider identification number. This rule will align TRICARE with Medicare’s policy. Comments on this proposed rule will be accepted until Tuesday, February 19, 2019. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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During the November Centers for Medicare and Medicaid Services (CMS) National Provider call with inpatient rehabilitation facilities (IRFs), CMS responded to a question related to the counting of minutes of therapy provided by a therapy student that these minutes would not count, regardless of the level of supervision.

This triggered much confusion and led to the therapy professional associations requesting a meeting with CMS to discuss and address this and their concerns surrounding this response. After this collaborative effort between these associations and CMS, CMS issued a clarification of its position on therapy students in IRFs.

CMS has noted that student therapists may participate in therapy provided in an IRF if the student is appropriately supervised, and that the time spent with the student may count towards satisfying intensity of therapy requirements for IRFs. Cited directly from the clarification:

“Regarding the IRF intensive rehabilitation therapy program requirement in 42 CFR 412.622(a)(3)(ii), CMS’s current policy does not prohibit the therapy services furnished by a therapy student under the appropriate supervision of a qualified therapist or therapy assistant from counting toward the intensive rehabilitation therapy program. However, IRFs provide a very intensive hospital level of rehabilitation therapy to some of the most vulnerable patients. To ensure the health and safety of this vulnerable population, CMS expects that all student therapy services will be provided by students under the supervision of a licensed therapist allowed by the hospital to provide such services.”

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

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The Centers for Medicare and Medicaid Services (CMS) released Change Request (CR) 11055, “Annual Update to the Per-Beneficiary Therapy Amounts.” This CR provides information on the annual per-beneficiary incurred expense amounts, now known as the KX modifier thresholds, and related policy updates for calendar year (CY) 2019. These amounts were previously associated with the financial limitation amounts (therapy caps) before the application of the therapy caps was repealed when the Bipartisan Budget Act (BBA) of 2018 was signed into law.

For CY 2019, the KX modifier threshold amount for physical therapy (PT) and speech-language pathology (SLP) services combined is $2,040. For occupational therapy (OT) services, the CY 2019 threshold amount is $2,040.

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

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