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Tags Posts tagged with "cms final rule"

cms final rule

On July 31, 2017, the Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2018 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule. Some of the key provisions contained in the final rule include:

 

Updates to IRF Payment Rates

Update to the Standard Payment Rates

CMS finalized an update to the IRF PPS payments to reflect a 1.0 percent increase factor, in accordance with section 1886(j)(3)(C)(iii) of the Social Security Act, as added by section 411(b) of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). An additional approximate 0.1 percent decrease to aggregate payments due to updating the outlier threshold results in an overall estimated update for FY 2018 of approximately 0.9 percent (or $75 million), relative to payments in FY 2017.

 

Update to CMG Weights, Lengths of Stay and Comorbidities

CMS updated the Case Mix Group (CMG) weights based on FY 2015 IRF cost report data and the FY 2016 IRF claims data, as well as the average lengths of stay (ALOS) per CMG. The final rule estimates 99.3 percent of all IRF cases are in CMGs and tiers that would experience less than a five percent change in the CMG relative weight under their proposal.

 

Rural Adjustment Transition

FY 2018 is the third and final year of the phase-out of the 14.9 percent rural adjustment for the 20 IRF providers that were designated as rural in FY 2015 and changed to urban under the new Office of Management and Budget (OMB) delineations in FY 2016. As a result, the rural adjustment for these IRF’s will no longer be applied.

 

ICD-10-CM Presumptive Compliance Coding Changes 

CMS made refinements to the ICD-10-CM lists used in determining IRFs’ presumptive compliance with the 60 Percent Rule. The complete lists of the adopted code revisions are available for download on the IRF Data Files website. CMS notes that the version of these finalized lists will constitute the baseline for any future updates to the presumptive methodology lists. The changes will be effective for discharges on or after October 1, 2017. CMS adopted only those coding changes that will increase the number of cases counting toward presumptive compliance and did not adopt any changes that would remove codes from counting toward the presumptive compliance threshold. CMS also stated that since it is not making any negative changes, it would consider the comments it received on the need for a delayed effective dates should any of these negative changes occur in future rulemakings.

For FY 2018, the following refinements to the ICD-10-CM lists used in determining IRFs’ presumptive compliance to ensure that these lists reflect as accurately as possible the types of patients that should count presumptively toward the 60 percent rule were finalized by:

  • Counting certain ICD-10-CM diagnosis codes for patients with traumatic brain injury and hip fracture conditions; and
  • Revising the presumptive methodology list for major multiple trauma by counting IRF cases that contain two or more of the ICD-10-CM codes from three major multiple trauma lists in the specified combinations.

CMS did not finalize the proposal to remove certain ICD-10-CM codes from the presumptive methodology at this time indicating they would continue to monitor and consider their appropriateness for inclusion on the presumptive methodology lists for future policy development and rulemaking.

 

Other Policy Changes

CMS proposed several changes for the purposes of eliminating redundancies and simplifying administrative burden for providers and for the agency and finalized the following:

  • Remove the 25 percent payment penalty for late submissions of the IRF PAI beginning October 1, 2017;
  • Remove the voluntary swallowing assessment item (Item 27) in the IRF PAI beginning October 1, 2017; and
  • Use the height/weight items on the IRF PAI (items 25A and 26A) to determine patients’ BMI greater than 50% for cases of lower extremity single joint replacement.

 

IRF Quality Reporting Program (QRP)

Under the IRF QRP, the applicable annual payment update for any IRF that does not submit the required data to CMS is reduced by 2 percentage points. In this final rule, CMS is finalizing the replacement of the current pressure ulcer measure with an updated version of that measure, as well as the removal of the All-Cause Unplanned Readmission Measure for 30 Days Post-Discharge from IRFs (NQF #2502). CMS is also finalizing the public display of six additional quality measures on the IRF Compare website in calendar year 2018.

 

In addition to the proposals related to quality measures and public reporting, CMS is finalizing that the data IRFs submit on the measure Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) meet the definition of standardized patient assessment data for the FY 2019 IRF QRP. For the FY 2020 IRF QRP, CMS is finalizing that the data IRFs submit on the measures Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631) and Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury meet the definition of standardized patient assessment data. However, in response to the comments received for the FY 2020 program year, CMS is not finalizing the proposed additional standardized data elements.

 

Request for Information

CMS also included a Request for Information (RFI) in the proposed rule for continuing feedback on the Medicare Program. Input was requested on potential regulatory, sub-regulatory, policy, practice and procedural changes to make the delivery system less bureaucratic and complex, reduce burden for clinicians and providers, and increases quality of care while decreasing cost. CMS said it would not respond to RFI comment submissions in the final rule, but rather will actively consider all input in developing future regulatory proposals or future sub-regulatory guidance. There was no response provided in the final rule.

 

The final rule will be published in the August 3, 2017 Federal Register, which will be sent to members upon publication.

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On January 17, 2017, the Centers for Medicare and Medicaid Services (CMS) published the final rule in the Federal Register that finalizes changes to the Medicare benefit claim appeals processes that were proposed on July 5, 2016. This final rule is part of the Department of Health and Human Services (HHS) approach for addressing the increasing number of appeals and the current backlog of claims waiting to be adjudicated. This final rule includes new and revised rules that expand the pool of available Office of Medicare Hearings and Appeals (OMHA) adjudicators; increase decision-making consistency among the levels of appeal; and improve efficiency by streamlining the appeals process so less time is spent by adjudicators and parties on repetitive issues and procedural matters. These regulations become effective on March 20, 2017.

The Centers for Medicare and Medicaid Services (CMS) published a final rule in the September 16, 2016 Federal Register that establishes national emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers to plan adequately for both natural and man-made disasters, and coordinate with federal, state, tribal, regional, and local emergency preparedness systems. It will also assist providers and suppliers to adequately prepare to meet the needs of patients, residents, clients, and participants during disasters and emergency situations. The effective date of the regulations are effective on November 15, 2016.

The Centers for Medicare and Medicaid Services (CMS) released a final rule in the May 4, 2016 Federal Register that updates health care facilities’ fire protection guidelines to improve protections from fire for Medicare beneficiaries in facilities.

The new guidelines apply to hospitals; long-term care (LTC) facilities; critical access hospitals; inpatient hospice facilities; programs for all-inclusive care for the elderly; religious non-medical health care institutions; ambulatory surgical centers (ASCs); and intermediate care facilities for individuals with intellectual disabilities (ICF-IID). This rule adopts updated provisions of the National Fire Protection Association’s (NFPA) 2012 edition of the Life Safety Code, as well as provisions of the NFPA’s 2012 edition of the Health Care Facilities Code.

Some of the main provisions in the final rule include:

  • Health care facilities located in buildings that are taller than 75 feet are required to install automatic sprinkler systems within twelve years after the rule’s effective date;
  • Health care facilities are required to have a fire watch or building evacuation if their sprinkler system is out of service for more than ten hours;
  • The provisions offer LTC facilities greater flexibility in what they can place in corridors;
  • Fireplaces will be permitted in smoke compartments without a one hour fire wall rating;
  • Cooking facilities now may have an opening to the hallway corridor;
  • For ASCs, all doors to hazardous areas must be self-closing or must close automatically; and
  • Expanded sprinkler requirements for ICF-IIDs.

Health care providers affected by this rule must comply with all regulations within 60 days of the May 4, 2016 publication date, unless otherwise specified in the final rule.

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The Centers for Medicare and Medicaid Services (CMS) published the final rule that updates the fiscal year (FY) 2016 Medicare payment policies and rates for the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) and the IRF Quality Reporting Program (IRF QRP) in the August 6, 2015 Federal Register. Highlights of the final rule are provided below.

Changes to the Payment Rates: CMS is updating the IRF PPS payments for FY 2016 to reflect an estimated 1.7 percent increase (reflecting a new IRF-specific market basket estimate of 2.4 percent, reduced by a 0.5 percentage point multi-factor productivity adjustment and a 0.2 percentage point reduction required by law). An additional 0.1 percent increase to aggregate payments due to updating the outlier threshold results in an overall update of 1.8 percent (or $135 million), relative to payments in FY 2015.

No Changes to the Facility-Level Adjustments: As stated in the FY 2015 IRF PPS final rule, CMS froze the facility-level adjustment factors at the FY 2014 levels for FY 2015 and all subsequent years. For FY 2016, CMS will continue to hold the facility-level adjustment factors at the FY 2014 levels as they continue to monitor the most current IRF claims data available to assess the effects of the FY 2014 changes.

ICD-10-CM Conversion: In the FY 2015 IRF PPS final rule, CMS finalized conversions from the International Classification of Diseases, 9th Revision, Clinical Modification (ICD-9-CM) to the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for the IRF PPS, which will be effective when ICD-10-CM becomes the required medical data code set for use on Medicare claims and IRF PAI submissions. The implementation date for ICD-10-CM is October 1.

IRF-specific Market Basket: For FY 2016, CMS is finalizing an IRF-specific market basket to replace the Rehabilitation, Psychiatric and Long-Term Care market basket. The IRF market basket is based on 2012 data (the RPL market basket is based on 2008 data). The IRF market basket is derived from using both freestanding and hospital-based IRF Medicare cost report data from FY 2012.

Changes to the Wage Index: CMS finalized its proposal for transitioning to the wage index associated with the new Office of Management and Budget delineations without any modifications. A one-year blended wage index will be provided for all IRFs, and a three-year phase-out of the rural adjustment for IRFs that were deemed rural in FY 2015 but are considered urban under the new delineations. CMS will apply the one year blended wage index in FY 2016 for all geographic areas, to assist IRFs in adapting to these changes.

  • FY 2015 rural IRFs classified as urban in FY 2016 will receive two-thirds of the FY 2015 rural adjustment in FY 2016, as well as the blended wage index.
  • For FY 2017, these IRFs will receive the full FY 2017 wage index and one-third of the FY 2015 rural adjustment.
  • For FY 2018, these IRFs will receive the full FY 2018 wage index without a rural adjustment.

Changes to the IRF Quality Reporting Program (QRP): The Improving Medicare Post-Acute Care Transformation Act of 2014 (“IMPACT” Act) added Section 1899B to the Social Security Act (the Act) to require that IRFs report data on measures that satisfy measure domains specified in the Act. These same measures are to be implemented in long-term care hospitals, IRFs, skilled nursing facilities and home health agencies. This final rule adopts 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 changes in function and cognitive function; and incidence of major falls. IRFs that fail to submit the required quality data to CMS will be subject to a 2 percentage point reduction to their applicable FY annual increase factor.

Finalized Changes:

The domains specified by the IMPACT Act, and the quality measures finalized, 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; Endorsed on July 23, 2015)
  • Domain 3: Incidence of major falls:
    • Quality Measure: Application of the “Percent of Residents Experiencing One or More Falls with Major Injury” (NQF #0674)

In addition to the measures listed above, CMS adopted four additional functional status quality measures, and completed 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.

Additionally, CMS will begin publically reporting IRF quality data in the fall of 2016. This includes a 30-day period for review and correction of quality data prior to public display.

Finally, CMS is temporarily suspending their previously finalized data validation policy in order to allow time to develop a more comprehensive policy that will potentially decrease the burden on IRF providers, allow CMS the ability to establish an estimation of accuracy related to quality data submitted to them, and facilitate the alignment of the IRF validation policy with that of other CMS quality reporting programs policies.

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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.