Medical Rehab

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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.

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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.

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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.

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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.

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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.

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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.

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The Centers for Medicare and Medicaid Services (CMS) has released the calendar year (CY) 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. The proposed rule would revise the Medicare hospital OPPS and the Medicare ambulatory surgical center (ASC) payment system for calendar year 2019. Included are proposed changes to the amounts as well as factors used to determine the payment rates and update and refine the requirements for the quality reporting programs (QRP). Some of the proposed highlights include a proposal to pay for visits at excepted off-campus provider-based departments at a Physician Fee Schedule (PFS) equivalent payment rate, which would result in lower copayments for beneficiaries and a savings to the Medicare program; reduction to the number of measures required to report under their quality reporting programs; and modifying the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) patient experience of care survey measure by removing the three recently revised pain communication questions beginning with January 1, 2022 discharges, which would avoid any potential unintended consequences of possible opioid overprescribing.

The proposed rule will be published in the July 31, 2018 Federal Register. Comments will be accepted through September 24, 2018. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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Presented by

Wojdak Gold on Dark

Tuesday, September 11, 2018 at 2:00 pm

RCPA is offering an exciting opportunity, exclusively for its members – an educational webinar regarding the statewide hospital assessment with featured presenters Wojdak Government Relations.  During this hour-long webinar, members will learn about the Commonwealth’s Medicaid payment and policy landscape, the current status of the hospital assessment, and potential future opportunities for freestanding medical rehabilitation hospitals. Please SAVE THE DATE: Tuesday, September 11, 2018 at 2:00 pm — a formal invitation will be sent soon. Contact Melissa Dehoff with questions about this webinar.

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The Energy and Commerce (E&C) Health Subcommittee has scheduled a hearing for Thursday, July 26, 2018 at 10:00 am. The hearing is entitled MACRA and MIPS: An Update on the Merit-based Incentive Payment System. This will be the fourth oversight hearing on the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. Members of the Subcommittee will hear from witnesses on the importance of fee-for-service as an option for certain physicians in the traditional Medicare and how the Merit-based Incentive Payment System (MIPS) has acted as a way to streamline quality programs, provided new financial opportunities for providers to participate and transition to new models of care. The witness list and testimony for the hearing will be posted to the E&C website as they are received. The hearing webcast will also be available. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with any questions.

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It has been reported that the Centers for Medicare and Medicaid Services (CMS) has issued letters of non-compliance to Inpatient Rehabilitation Facilities (IRFs) specific to the IRF quality reporting program (QRP) requirements for the data collection period affecting federal fiscal year (FFY) 2019 reimbursement. IRFs that did not meet the IRF QRP reporting requirements will receive a two percent payment reduction on their IRF prospective payment system (PPS) annual increase factor in FY 2019.

IRFs found to be non-compliant should have received notification from their Medicare Administrative Contractor (MAC) and are also expected to receive a letter in their provider Certification and Survey Provider Enhanced Reporting (CASPER) folder with specific details regarding the missing quality reporting data. Additional information on the data collections requirements and submission timeframes for FY 2019 compliance determination can be found in the CMS Data Collection & Final Submissions table posted on the CMS website, as well as the CMS IRF QRP website.

IRFs that feel they have received a non-compliance notification letter in error may request CMS reconsideration of the decision. Providers have 30 days to file a reconsideration request. Detailed filing instructions can be found on the IRF Quality Reporting Reconsideration and Exception & Extension web page.