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Medical Rehab

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The Centers for Medicare and Medicaid Services (CMS) has scheduled a call on Thursday, June 21, 2018 at 2:00 pm that will focus on and provide additional information about the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. During the call, CMS will answer frequently asked questions (FAQs) on quality measures, standardized data elements, the CMS data element library, and future directions of the IMPACT Act. Members that wish to participate in the call must register. Send any questions or request assistance with registration via email.

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The Centers for Medicare and Medicaid Services (CMS) has posted a number of various inpatient rehabilitation facility patient assessment instrument (IRF PAI) resources to their website, including the RTI International Report on patient assessment data elements.

Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Proposed Rule for FY 2019: Reminder: Comments are due by June 26, 2018. See May 4, 2018 RCPA Info for additional information on the proposed provisions.

PROPOSED IRF-PAI Version 3.0: The proposed assessment tool indicates an effective date of October 1, 2019. However, the fiscal year (FY) 2019 IRF prospective payment system (PPS) proposed rule indicates it will be effective in FY 2020.

Change Table: Proposed IRF-PAI Version 3.0 – Effective October 1, 2019 (FY 2020) – Changes from Version 2.0 to 3.0: This table highlights the differences between the IRF PAI Version 3.0 and IRF PAI Version 2.0.

RTI International Report: Analyses to Inform the Potential Use of Standardized Patient Assessment Data Elements in the Inpatient Rehabilitation Facility Prospective Payment System: This report includes a summary by RTI on the use of  assessment data in the current IRF PPS and describes the process used to substitute data from the quality indicators sections of the IRF PA into the IRF PPS. The report also presents the case-mix groups (CMGs) and payment weights based on those elements that CMS proposes for FY 2020.

Contact Melissa Dehoff with questions.

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The Centers for Medicare and Medicaid Services (CMS) released the display copy of the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

Key highlights from the proposed rule:

  • Proposed Removal of FIM: Being the most significant proposal, CMS proposes to remove the Functional Independence Measure (FIM) instrument, as well as the associated Functional Modifiers, from the IRF Patient Assessment Instrument (PAI).
  • Changes to the IRF Coverage Requirements: There are several proposed changes to the coverage requirements:
    • Post-Admission Physician Evaluation: CMS is proposing allowing the post-admission physician evaluation to count towards one of the required three weekly face-to-face physician visits.
    • Physician Attendance at Interdisciplinary Team Meeting: CMS is proposing to amend the regulations to allow the rehabilitation physician leading the required interdisciplinary team meeting to attend the meeting remotely (via video conference or teleconference).
    • Admission Order Documentation Requirement: CMS is proposing to remove the requirement that there be a physician order for inpatient care when the patient is admitted since this requirement is included under the Medicare Conditions of Participation (CoPs) regulations.
    • Requests for Information on Physician Requirements: CMS is seeking information on specific areas where they can alleviate burden through changes to requirements pertaining to physician supervision in an IRF. CMS is also seeking information on the use of non-physician practitioners (NPPs) in IRFs.
  • Proposed Changes to IRF QRP – CMS is proposing 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); and
    • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680).
  • Display of Functional Outcomes Measures Data on IRF Compare: CMS proposes to begin publicly displaying data on the following assessment-based measures in calendar year (CY) 2020 on IRF Compare:
    • Change in Self-Care (NQF: #2633);
    • Change in Mobility Score (NQF: #2634);
    • Discharge Self-Care Score (NQF: #2635); and
    • Discharge Mobility Score (NQF: #2636)

CMS has published a fact sheet that provides additional information on the proposed rule. The proposed rule will be published in the May 8, 2018 Federal Register, with comments being due by June 26, 2018.

The Department of Health and Human Services (HHS) has committed to improving the Medicare claims appeals process. This commitment includes the internal implementation of an expanded Settlement Conference Facilitation (SCF) program by the Office of Medicare Hearings and Appeals (OMHA). SCF is an alternative dispute resolution process at OMHA that gives certain providers and suppliers an opportunity to resolve their eligible Part A and Part B appeals.

 

In order to educate all Medicare Part A and Medicare Part B providers and suppliers who have OMHA or Medicare Appeals Council appeals pending, an SCF Expansion Open Door Call will be held on Tuesday, May 22, 2018 at 1:30 pm. The call will focus on the logistics of the SCF process and SCF eligibility criteria. Providers that plan to join the call are encouraged to submit their questions in advance via email and include “SCF May 22 Call” in the subject line. To participate, registration is required. Additionally, providers are encouraged to read the updated SCF expansion materials, including an SCF Expansion Frequently Asked Questions document, on the website.

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The Centers for Medicare and Medicaid Services (CMS) issued revised Change Request (CR) 10531 (MLN Matters Number: 10531). The article, “Claims Processing Actions to Implement Certain Provisions of the Bipartisan Budget Act of 2018,” was revised and provides direction to Medicare Administrative Contractors (MACs) to reprocess claims related to several provisions of the Bipartisan Budget Act of 2018. The initial MLN article was released on March 26, 2018.

On February 9, 2018, Congress passed the Bipartisan Budget Act of 2018, which contains a number of provisions that extend certain Medicare Fee For Service (FFS) policies, including Ambulance add-on payment provisions and a three percent home health Rural Add-on Payment. In addition, the Act permanently repeals the outpatient therapy caps beginning on January 1, 2018, while retaining the requirement to submit the KX modifier for services in excess of the prior cap amounts. Due to the retroactive effective dates of these provisions, various Medicare FFS claims shall be reprocessed. This CR provides guidance to MACs regarding Medicare FFS claims reprocessing requirements and time frames.

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Registration is now open for providers interested in attending a free two-day, in person training session on the inpatient rehabilitation facility quality reporting program (IRF QRP). The session, scheduled for Wednesday, May 9 –  Thursday, May 10, 2018 in Baltimore, MD will be hosted by the Centers for Medicare and Medicaid Services (CMS).

The primary focus of this “Train-the-Trainer” event will be to provide those responsible for training staff at IRFs with information about IRF QRP changes and updates to the Inpatient Rehabilitation Facility–Patient Assessment Instrument (IRF-PAI) v. 2.00, effective October 1, 2018. Topics will include information on new items, including those associated with the drug regimen review quality measure. Presenters will also discuss resources available on the CMS website, support available through the IRF help desks, public reporting, and use of reports to aid providers in better understanding the IRF QRP.

Additional information, including the registration page and agenda, is posted on the CMS website. Interested providers are encouraged to register as soon as possible as the in-person training is limited to the first 200 people on a first-come, first-served basis.

The training will not be available via webcast, but will be available via a link from the IRF QRP training web page after the training has completed.

The Pennsylvania Department of Health (DOH) has created a brain injury identification wallet card. The card was created as a result of a telephone call from an individual with a brain injury who moved from another state. The individual was inquiring as to whether PA had a card that could be used in emergent situations that would easily identify him as having a brain injury and his symptoms. The wallet card is available on the DOH website. The intent of the card is to provide a document for individuals with a brain injury that could be used to communicate their symptoms and emergency information to emergency personnel or the public.

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Today, the Centers for Medicare and Medicaid Services (CMS) released the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) transfer of health measures for public review and comment. CMS contracted with the RTI International and Abt Associates to develop cross-setting post-acute care transfer of health information and care preferences quality measures in alignment with the IMPACT Act.

As part of its measure development process, CMS is requesting comments on two draft measure specifications, including:

  1. Medication Profile Transferred to Provider
  2. Medication Profile Transferred to Patient

Additional information is provided on the public comment page on the CMS website. The public comment period closes on May 3, 2018.

On March 9, 2018, Representative Tina Pickett introduced House Resolution 741 designating the month of March 2018 as “Brain Injury Awareness Month” in Pennsylvania. The resolution was adopted (188–0) on March 14, 2018. A similar co-sponsorship memo was introduced in the Senate by Senator Schwank and will be voted on in the near future. March is nationally recognized as Brain Injury Awareness Month as well.

The Administration for Community Living (ACL) recently posted a number of grant opportunities associated with traumatic brain injuries (TBI).

On February 7, 2018, College and Career Success for Students with Serious Mental Illness or Traumatic Brain Injury was posted. The purpose of this grant opportunity is to generate new knowledge about the effectiveness of interventions to improve college education and employment outcomes of people with serious mental illness or traumatic brain injury. The funding for this grant is $475,000 and the closing date for applications is April 9, 2018.

On February 14, 2018, two additional grant opportunities were posted:

Traumatic Brain Injury State Partnership Program Partner State Funding Opportunity, whose purpose is to create and strengthen a system of services and supports that maximizes the independence, well-being, and health of persons with TBI across the lifespan, their families, and their caregivers. Through the TBI State Partnership Program, the goal is two-fold:

  1. To allow states to strengthen and grow their capacity to support and maintain a system of services and supports that will help maximize the independence, well-being, and health of persons with TBI; and
  2. To learn from and call upon the expertise of states that have built and maintained a strong and sophisticated state TBI infrastructure. This grant opportunity has an award ceiling of $150,000.

The Traumatic Brain Injury State Partnership Program Mentor State Funding Opportunity has a purpose to create and strengthen a system of services and supports that maximizes the independence, well-being, and health of persons with TBI across the lifespan, their families, and their caregivers. Through the TBI State Partnership Program, the goal is two-fold:

  1. To help states strengthen and grow their capacity to support and maintain a system of services and supports that will help maximize the independence, well-being, and health of persons with TBI; and
  2. To learn from and call upon the expertise of states that have built and maintained a strong and sophisticated state TBI infrastructure. For the 2018 funding cycle, ACL is funding two tiers of grantees that will work together to maximize the program’s impact nationally.

Partner State Grants will provide funding to states for building and enhancing basic infrastructure, while Mentor State Grants will provide funding to more established states to maintain and expand their infrastructure and also to mentor Partner States and work together with other Mentor States and ACL to improve the national impact of the TBI program. Applicants must agree to provide the required 2:1 state match, support a state TBI advisory board, provide at least one full-time dedicated staff person, create an annual TBI state plan, create and/or expand their state TBI registry, work with one or more Partner States to increase their capacity to provide access to comprehensive and coordinated services for individuals with TBI and their families, and work with other Mentor States and ACL to improve national coordination and collaboration around TBI services and supports.

ACL encourages organizations that are interested and qualify to apply for both funding opportunity announcements; however, ACL will not make more than one award to a single applicant. Applicants that score in the fundable range on both reviews may choose which award they wish to receive. Applicants that are only interested in receiving a Partner State Grant do not need to apply for this opportunity. This grant opportunity has an estimated award ceiling of $300,000. The closing date for both of these grant opportunities is April 16, 2018.

RCPA will be working with the Pennsylvania Department of Health (DOH) to review the grant applications and discuss next steps surrounding these opportunities.