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Medical Rehab

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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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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.

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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.

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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.

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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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