RCPA has been in communication with the American Medical Rehabilitation Providers Association (AMRPA), who has been working with the Centers for Medicare and Medicaid Services (CMS) to ensure inpatient rehabilitation facilities (IRFs) do not face inappropriate non-compliance penalties related to the IRF Patient Assessment Instrument (PAI) version 4.0 that is set to go into effect tomorrow (October 1, 2022). One particular concern is new items in version 4.0 do not include a “skip logic” to account for unplanned discharges that classify as incomplete stays. This oversight could lead to many IRFs not meeting the 95 percent data completion threshold for the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP).
Yesterday, CMS released a statement on the issue along with a Question & Answer (Q&A) document. CMS also noted that the agency will determine if a permanent fix is necessary and will release any related guidance or data specifications in the coming weeks.