Medical Rehab

0 1750

On July 14, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule in the Federal Register, announcing the implementation of a new Medicare Part A and B payment model called the Comprehensive Care for Joint Replacement (CCJR) model. Under this model, acute care hospitals in 75 selected geographic areas would receive retrospective bundled payments for episodes of care for lower extremity joint replacement or reattachment of a lower extremity. All related care within 90 days of hospital discharge from the joint replacement procedures will be included in the episode of care.

CMS anticipates the proposed CCJR model would benefit Medicare beneficiaries by improving the coordination and transition of care, improving the coordination of items and services paid through Medicare fee-for-service, encouraging more provider investment in infrastructure and redesigned care process for higher quality and more efficient service delivery, and incentivizing higher value care across the inpatient and post-acute care spectrum spanning the episode of care. According to CMS, hip and knee replacements are the most common inpatient surgery for Medicare beneficiaries and can require lengthy recovery and rehabilitation periods.

CMS proposes to test CCJR for a five year performance period, beginning January 1, 2016, and ending December 31, 2020. Comments will be accepted on the proposals contained in the proposed rule, as well as other alternatives or suggestions, through September 8. Contact Melissa Dehoff at RCPA with questions.

0 1830

The Centers for Medicare and Medicaid Services (CMS) has released an updated inpatient rehabilitation facility patient assessment instrument (IRF PAI) training manual that includes updated information on new items that become effective for IRF discharges occurring on or after October 1. These new items, including the arthritis attestation item and therapy information, were finalized in the IRF prospective payment system fiscal year 2015 final rule. The Updated IRF PAI Training Manual, Helpful Resources Document and Section 2 (Item by Item Coding Instructions) are located in the “Downloads” section of the IRF PAI web page. CMS has also made available a YouTube video slideshow from the January 2015 national provider call that focused on training providers how to code and complete these new items on the IRF PAI.

The National Council released the information described below on July 9. RCPA will be accepting comments to provide to the National Council until August 3.

The Department of Labor (DOL) has proposed extending its overtime pay exemption rules to include employees making up to $50,440 next year, a change that could affect up to 5 million workers. Under the new proposal, the salary threshold for overtime pay would rise to $970 per week ($50,440 per year) in 2016. The current level of $455 per week ($23,660) was established in 2004, and it is below the poverty line for a family of four.

Unlike the current exemption threshold, the newly proposed threshold is linked not to a specific salary amount, but to the 40th percentile of wage earners. Thus, the new salary threshold will automatically update over time. The proposed regulation affects white collar workers (executive, administrative, and professional). More information is available in this fact sheet.

The DOL has posted the proposal online, giving people the opportunity to submit written comments on or before September 4. The White House has stated that the DOL will release a final rule next year after reviewing and considering these comments.

The Department of Human Services has announced the July training schedule and related information for the approved and required Medication Administration Training. Training will be available online and at various locations across the Commonwealth. Future classroom training sessions are being scheduled throughout the year; announcements will be released when finalized. Classroom training sites have limited capacity, and training candidates from agencies with no certified medication administration staff are required to complete the online course work before they are permitted to attend the classroom training.

Medication administration training is required for designated staff working in: adult training facilities, adult day services, personal care homes, assisted living residences, child residential and residential treatment and day treatment facilities, community homes for individuals with an intellectual disability, and intermediate care facilities. Questions about the information in the training document can be directed to (717) 221-1630 or email.

0 1401

The Centers for Medicare & Medicaid Services (CMS) has contracted with RTI International and Abt Associates to develop potentially preventable readmission measures, in alignment with the Improving Post-Acute Care Transformation Act of 2014 (known as the IMPACT Act). As part of its measure development process, CMS asks contractors to convene groups of stakeholders and experts who contribute direction and thoughtful input to the measure contractor during measure development and maintenance. The purpose of this project is to develop, maintain, re-evaluate, and implement outcome and process quality measures that are reflective of quality care for the PAC settings, to support CMS quality and Quality Improvement Organization Program missions that include the Long-Term Care Hospital Quality Reporting Program (QRP), the Inpatient Rehabilitation Facility QRP, the Nursing Home/Skilled Nursing Facility QRP, and the Home Health QRP. The cross-setting readmissions measures will be applicable to all post-acute care settings.

The Technical Expert Panel (TEP) will be selected of approximately 10-15 individuals to provide input, and will be comprised of individuals with the following areas of expertise and perspectives:

  • Cross-setting expertise; post-acute care, skilled nursing facility, inpatient rehabilitation facility, long-term care hospital, home health agency
  • Consumer/patient/family perspective
  • Performance measurement with regard to hospital readmissions
  • Quality improvement
  • Purchaser/insurer perspective
  • Research methodology, including risk adjustment
  • Data collection and implementation perspective
  • Health and health care disparities

The TEP requirements, including time commitment information, can be obtained on the Technical Expert Panel Nomination Form.

Please act quickly if you or someone else from your organization is interested in applying. The deadline to submit the completed TEP nomination form, etc. is June 1.

0 1249

The Centers for Medicare and Medicaid Services (CMS) continues to offer various resources and education efforts to assist providers in preparing for the ICD-10 implementation on October 1.

National Provider Call: June 18, 1:30 – 3:00 pm
During this national provider call, CMS subject matter experts will present strategies and resources to help you prepare. Agenda topics include:

  • National implementation update and preparation strategies;
  • ICD-10-PCS Section X for new technologies;
  • Testing update; and
  • Provider resources.

Providers are encouraged to register early as space may be limited.

New ICD-10 Videos: Impact on Inpatient Hospital Payment and Medicare Testing Plans
The following videos were recorded from presentations at the CMS ICD-10 Coordination and Maintenance Committee on March 18:

ICD-10 End-to-End Testing in July (Final Opportunity): Forms Accepted May 11 – May 22
During the week of July 20-24, a final sample group of providers will have the opportunity to participate in ICD-10 end-to-end testing with Medicare Administrative Contractors (MACs) and the Common Electronic Data Interchange (CEDI) contractor. CMS is accepting additional July volunteers from May 11 through 22; approximately 850 volunteer submitters will be selected. This nationwide sample will yield meaningful results, since CMS intends to select a broad cross-section of provider, claim, and submitter types, including claims clearinghouses that submit claims for large numbers of providers. Note: Testers who are participating in the January and April end-to-end testing weeks are able to test again in July without re-applying. 

To volunteer as a testing submitter:

  • Volunteer forms are available on your MAC website
  • Completed volunteer forms are due May 22
  • CMS will review applications and select additional July testers
  • The MACs and CEDI will notify the volunteers selected to test and provide them with the information needed for the testing by June 12

If selected, testers must be able to:

  • Submit future-dated claims
  • Provide valid National Provider Identifiers (NPIs), Provider Transaction Access Numbers (PTANs), and beneficiary Health Insurance Claim Numbers (HICNs) that will be used for test claims. This information will be needed by your MAC for set-up purposes by the deadline on your acceptance notice; testers will be dropped if information is not provided by the deadline.

Any issues identified during testing will be addressed prior to ICD-10 implementation. Educational materials will be developed for providers and submitters based on the testing results.

Participate in Final ICD-10 Acknowledgement Testing Week: June 1 through June 5

To assist providers in preparing for the transition to ICD-10, CMS offers acknowledgement testing for current direct submitters (providers and clearinghouses) to test with the MACs, and the Durable Medical Equipment (DME) MAC Common Electronic Data Interchange (CEDI) contractor, anytime up to the October 1 implementation date. Acknowledgement testing provides submitters access to real-time help desk support and allows CMS to analyze testing data. The final acknowledgement testing week will be June 1-5. Information is available on the MAC website or through your clearinghouse.

0 1812

On April 23, the Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2016 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule. RCPA will review the provisions contained within the proposed rule with members, for their input, to include in comments to CMS. Highlights of the proposed rule are provided below.

Proposed Changes to the IRF Quality Reporting Program
The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) added Section 1899B to the Social Security Act to require that IRFs report data on measures that satisfy domains specified under the IMPACT Act, which will also be implemented in other post-acute care (PAC) settings (Skilled Nursing Facilities, Long-Term Care Hospitals, and Home Health Agencies). This rule proposes to adopt measures that satisfy three of the quality domains required by the IMPACT Act in FY 2016: skin integrity and changes in skin integrity, functional status, cognitive function, and incidence of major falls. IRFs that fail to submit the required quality data to CMS will be subject to a two percentage point reduction to their applicable FY annual increase factor.

The domains specified by the IMPACT Act and the quality measures proposed are as follows:

  • Domain 1. Skin integrity and changes in skin integrity:
  • Quality Measure: “Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened” (NQF #0678)
  • Domain 2. Functional status, cognitive function, and changes in function and cognitive function:
  • Quality Measure : Application of the “Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function” (NQF #2631; under review)
  • Domain 3. Incidence of major falls:
  • Quality Measure: Application of the “Percent of Residents Experiencing One or More Falls with Major Injury” (NQF #0674)

Additionally, CMS proposes to adopt four additional functional status quality measures, as well as proposing the previously finalized quality measure “All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from Inpatient Rehabilitation Facilities” (NQF #2502), in order to establish its newly NQF-endorsed status.

The four functional status quality measures under consideration include:

  • IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients (NQF #2633; under review);
  • IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients (NQF #2634; under review);
  • IRF Functional Outcome Measure: Discharge Self-Care Score for Medical Rehabilitation Patients (NQF #2635; under review); and
  • IRF Functional Outcome Measure: Discharge Mobility Score for Medical Rehabilitation Patients (NQF #2636; under review).

CMS proposes to publicly report IRF quality reporting program data beginning in fall 2016. A period of time will be provided for review and correction of quality data by IRFs prior to its publication of the performance data.

Continuation of Reporting Previously Collected IRF QRP Measures
For the FY 2018, adjustments to the IRF PPS annual increase factor, CMS is retaining previously discussed measures, including:

  • NHSN CAUTI Outcome Measure (NQF #0138);
  • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short-Stay) (NQF #0680);
  • Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short-Stay) (NQF #0678);
  • All-Cause Unplanned Readmission Measure for 30 Days Post-Discharge from IRFs (NQF #2502);
  • Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431);
  • NHSN Facility-Wide Inpatient Hospital-Onset MRSA Bacteremia Outcome Measure (NQF #1716); and
  • NHSN Facility-Wide Inpatient Hospital-Onset CDI Outcome Measure (NQF #1717).

A future update to the numerator of the quality measure Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) is being considered. This update would hold providers accountable for the reporting of unstageable pressure ulcers, including suspected deep tissue injuries (sDTIs). If this proposed change were to be implemented, the numerator of the quality measure would be updated to include unstageable pressure ulcers, including sDTIs, that are new or developed in the facility, as well as Stage 1 or 2 pressure ulcers that become unstageable due to slough or eschar (indicating progression to a Stage 3 or 4 pressure ulcer) after admission.

Proposed Changes to the IRF Prospective Payment System

  • Standard Payment Rate: The standard payment rate conversion factor is proposed to be increased in FY 2016 to $15,529 from the FY 2015 amount of $15,185. This amount is the result of a 2.7 percent market basket increase minus a productivity adjustment of 0.6 percent, minus a 0.2 percent legislative adjustment. CMS is also proposing a new rehabilitation only market basket.
  • Update to CMG Weights, Lengths of Stay and Comorbidities: CMS updated the Case Mix Group (CMG) weights using FY 2013 cost report data and the FY 2014 claims data and the lengths of stay (ALOS) per CMG.
  • Labor Related Share and Area Wage Adjustments: The proposed labor related share for FY 2016 is 69.6, a slight increase over FY 2015’s labor-related share of 69.294. CMS used the same methodology it has previously employed in calculating previous IRH/U labor-related shares.
  • Outlier Threshold: CMS updates the outlier threshold amount to $9,698 in order to maintain the outlier payments at three percent of total IRF payments in FY 2016. The national cost-to-charge ratio ceiling is set for FY 2016 at 1.36; the ceiling for rural IRFs is 0.569 and 0.437 for urban IRFs.
  • Changes to Facility Adjusters: CMS made significant changes to the methodology used to develop the facility-level adjustment factors in the FY 2014 IRF PPS final rule. For FY 2016, CMS continues to freeze the LIP, rural, and teaching adjustments at the FY 2014 levels, which are: LIP factor of 0.3177; rural adjustment at 14.9 percent; and teaching adjustment factor at 1.0163.

Revised Version of the IRF PAI
A revised version (FY 2017, version 1.4) of the inpatient rehabilitation facility patient assessment instrument (IRF PAI) has been published, to account for changes in measure reporting occurring as a consequence of the IMPACT Act. CMS has also published a chart that compares the IRF PAI versions 1.4 (effective FY 2017) and 1.3 (effective FY 2016).

The proposed rule will be published in the April 27, 2015 Federal Register. Comments on the provisions contained within this proposed rule will be accepted through June 22.