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CMS FY 2020 IRF PPS Final Rule

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On July 31, 2019, the Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2020 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule. This final rule is scheduled to be published in the Federal Register on August 8, 2019.

Key provisions contained in the final rule include:

  • Motor Score Provisions: Based on feedback received with the proposed rule, CMS is adopting an unweighted motor score to assign patients to case-mix groups (CMGs), rather than the use of a weighted motor score as originally proposed. CMS also finalized as proposed the removal of GG0170A1 (roll left and right) from the motor score (leaving 18 unweighted data items).
  • CMGs, Relative Weights, & Average Length of Stay: The final rule includes three additional CMGs than were included in the proposed rule:
    • Stroke RIC (01) will have 6 CMGs, compared to 7 in the proposed rule
    • Non-traumatic spinal cord injury RIC (05) will have 5 CMGs, compared to 4 in the proposed rule
    • Replacement of lower extremity joint RIC (08) will have 5 CMGs, compared to 4 in the proposed rule
    • Rheumatoid other arthritis CMG RIC (13) will have 5 CMGs, compared to 4 in the proposed rule
    • Major multiple trauma without brain or spinal cord injury RIC (15) will have 5 CMGs, compared to 4 in the proposed rule
  • Rebasing and Revising IRF Market Basket: CMS is rebasing and revising the IRF market basket to reflect a 2016 base year and is forecasted to be 2.9 percent.
  • Clarification of “Rehabilitation Physician”: CMS is amending the regulations to clarify that the determination as to whether a physician qualifies as a rehabilitation physician (that is, a licensed physician with specialized training and experience in inpatient rehabilitation) is to be determined by the IRF, as the provider is in the best position to make that determination.
  • Ensuring Quality: CMS finalized two new quality measures to implement the final requirements of the Improving Medicare Post-Acute Transformation (IMPACT) Act. Those two measures are: 1) Transfer of Health Information (TOH) from IRF to another Provider, and 2) Transfer of Health Information (TOH) from IRF to the Patient.
  • IRF Quality Reporting Program (QRP): CMS is adopting two new quality measures that satisfy the IMPACT Act domain pertaining to the transfer of health information when a patient is transferred or discharged from the IRF to another PAC provider or the home of the individual. Specifically, both of these measures would assess whether the IRF provides a reconciled medication list at the time of transfer or discharge. They also support the CMS Meaningful Measures initiative of promoting effective communication and coordination of care, specifically the meaningful measure area of the transfer of health information and interoperability. In addition, CMS is adopting a number of standardized patient assessment data elements

(SPADEs). These SPADEs assess key domain areas including functional status, cognitive function and mental status, special services, treatments and interventions, medical conditions and comorbidities, impairments, and social determinants of health (SDOH). The addition of these SPADEs to the IRF-Patient Assessment Instrument (IRF-PAI) will improve coordination of care and enable communication between PAC providers and other members of the health care community, aligning with CMS’ strategic initiative to improve interoperability. CMS is also updating the specifications for the Discharge to Community PAC IRF QRP measure to exclude baseline nursing home residents. CMS is also finalizing their policy to no longer publish a list of compliant IRFs on the IRF QRP website. CMS proposed to collect standardized patient assessment data and other data required to calculate quality measures using the IRF PAI on all patients, regardless of the patient’s payer; however, in response to stakeholder feedback, they have decided not to finalize this proposal.

The payment provisions contained in the final rule become effective for discharges on or after October 1, 2019 and the new quality reporting requirements go into effect on October 1, 2020. Contact RCPA Director of Rehabilitation Services Melissa Dehoff with questions.