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Tags Posts tagged with "IRF"

IRF

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The next phase of the Centers for Medicare and Medicaid Services (CMS) inpatient rehabilitation facility (IRF) review choice demonstration (RCD) is scheduled to be implemented in Pennsylvania on June 17, 2024, and will last for five years. This demonstration applies to only IRF providers physically located in Pennsylvania.

Between May 3, 2024, and June 2, 2024, IRFs must select either 100% pre-claim review or 100% post-payment claim review.

CMS has stated that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. This program reduces the number of Medicare appeals, improves provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

Novitas Solutions is the Medicare Administrative Contractor (MAC) for Pennsylvania and will process the IRF claims. In preparation for the implementation of IRF RCD, Novitas Solutions will be conducting their first webinar on April 24, 2024, from 1:00 pm – 2:30 pm. Registration to participate in this webinar is now open. Members are strongly encouraged to participate in this webinar to prepare for this demonstration. If the registration link does not work, please copy and paste the below link into your browser to register:
https://fcso.webex.com/webappng/sites/fcso/meeting/register/0fd87e2111f7446fa477d0a25f78674c?ticket=4832534b000000073a942d9e6f94601b6b106adc8f502bcee359653432e8c326edb0f50ebc253329&timestamp=1711559626291&RGID=re6663754d2fe70defe3195e29c69465a

In addition to information on the CMS website, Novitas Solutions has a dedicated website that provides a great deal of information and resources on IRF RCD.

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In order to avoid a potential 2 percent decrease in the annual payment update for fiscal year (FY) 2025 (October 2024 – September 2025), inpatient rehabilitation facilities (IRF) are reminded that they must submit complete data in calendar year (CY) 2023 for all quality measures that are a part of the IRF Quality Reporting Program (QRP).

IRF Patient Assessment Instrument (IRF-PAI) assessment data and data submitted via the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN) for July 1 – September 30 (Q3) of calendar year 2023 must be submitted no later than 11:59 pm on February 15, 2024.

The Centers for Medicare and Medicaid Services (CMS) contractor Swingtech sends informational messages to IRFs that are not meeting Annual Increase Factor (AIF) thresholds on a quarterly basis ahead of each submission deadline. These messages were sent late last week. IRFs are encouraged to check to see if any members of their QRP team received a message from the email address “QRPHelp@swingtech.com.” If members need to add or change the email addresses to which these messages are sent, please email QRP Help and be sure to include your facility name and CCN along with any requested email updates. Any IRFs who receive a Swingtech email message are encouraged to identify and review the measures stated as missing data for Q3 2023 ASAP, and resolve any data issues by the February 15 deadline.

Image by StockSnap from Pixabay

The Centers for Medicare and Medicaid Services (CMS) has released a short, animated explainer video, “Social Determinants of Health Items: Determining When a Proxy Response is Allowed,” for inpatient rehabilitation facilities (IRF), home health (HH), and long-term care hospital (LTCH) providers. CMS developed this video to assist providers in accurately determining when the use of a proxy response is allowed for the following Social Determinants of Health (SDoH) items: A1005. Ethnicity, A1010. Race, A1110. Language, A1250. Transportation, B1300. Health Literacy, and D0700. Social Isolation.

If you have questions about accessing the resources or feedback regarding the trainings, please email the PAC Training Inbox. Content-related questions should be submitted to the HH QRP Help Desk, IRF QRP Help Desk, or the LTCH QRP Help Desk.

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The Centers for Medicare and Medicaid Services (CMS) has released a number of additional and updated documents related to the inpatient rehabilitation facility (IRF) review choice demonstration (RCD). Included in these documents are:

  • An updated and revised Operational Guide — Clarifies key programmatic details regarding the different review choices and other facets of the demonstration.
  • Frequently Asked Questions Document — The FAQ focuses on major areas of confusion on the choice selection and submission processes, the Pre-Claim Review Track, and medical necessity determinations.
  • Transcript and Recording — From the June 27, 2023, special open-door forum on the IRF RCD.

Additional information about the IRF RCD can be found on the CMS IRF RCD web page.

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The Centers for Medicare and Medicaid Services (CMS) conducted a special open door forum on June 27, 2023, that focused on the Review Choice Demonstration (RCD) for inpatient rehabilitation facilities (IRF). Beginning August 21, 2023, the RCD will begin for IRF services in Alabama. CMS has shared that IRFs in Pennsylvania will be included in the next phase of the demonstration. For additional information, there is an RCD web page dedicated to this. The presentation from the June 27 special open door is also available.

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The Centers for Medicare and Medicaid Services (CMS) recently notified the American Medical Rehabilitation Providers Association (AMRPA) that the rollout of the Review Choice Demonstration (RCD) would begin on August 21, 2023, in Alabama. In previous information released about the RCD, Pennsylvania is most likely to be one of the next states in line for this rollout. Under this demonstration, CMS Medicare Administrative Contractors (MACs) will review all Medicare Fee-for-Service (FFS) claims in select states. CMS will utilize a dedicated website to provide updated information and resources to inpatient rehabilitation facility (IRF) stakeholders.

RCPA is working closely with AMRPA staff and will keep members apprised of developments and updates throughout the demonstration. The RCD website confirms that affected IRFs will have the option to elect pre-claim or post-payment review (and must use the same option for all claims).

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The Inpatient Rehabilitation Facility (IRF) Provider Preview Reports have been updated and are now available. These reports contain provider performance scores for quality measures, which will be published on Care Compare and the Provider Data Catalog during the Care Compare refresh in December 2022. For additional information, please visit the CMS IRF Quality Reporting Program (QRP) Public Reporting website. The deadline to review the information is October 17, 2022.

Last week, H.R.8746 — Access to Inpatient Rehabilitation Therapy Act of 2022 was introduced to ensure Medicare beneficiaries in inpatient rehabilitation facilities (IRFs) are able to access all skilled, medically necessary rehabilitation therapies that are most appropriate for their condition. This bill, also known as the “three hour rule bill,” would expand the current three hour rule in which Medicare requires IRF patients to be able to participate in, and benefit from, three hours of rehabilitation therapy per day, five days a week (or 15 hours over a seven day period). The current regulation only allows physical therapy (PT), occupational therapy (OT), speech therapy, and orthotics and prosthetics care to count towards the three hour requirement. As a result, many patients have difficulty accessing additional forms of therapy that may be more appropriate.

During the COVID-19 public health emergency (PHE), the three hour rule has been waived in its entirety. If the Access to Inpatient Rehabilitation Therapy Act is enacted, it would ensure that IRFs maintain flexibility after the expiration of the PHE. Most importantly, the legislation would allow certain therapies, including recreational therapy, cognitive therapy, and respiratory therapy, to count towards the three hour rule after the patient’s admission. These additional therapies and skilled modalities would be identified by the Secretary of Health and Human Services (HHS). At the time of admission, the existing three hour rule would still apply, ensuring that IRF admissions do not increase (and thus add to underlying costs for the Medicare program) due to the new flexibility.

This legislative solution has been developed over several years with Members of Congress and a group of stakeholders, including the American Medical Rehabilitation Providers Association (AMRPA), the American Academy of Physical Medicine & Rehabilitation (AAPM&R), the Brain Injury Association of America (BIAA), and the American Therapeutic Recreation Association (ATRA).

For additional information, please refer to Congressman Courtney’s press release.

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On July 13, 2022, the Centers for Medicare and Medicaid Services’ (CMS) Medicare Administrative Contractors (MACs) distributed notifications to inpatient rehabilitation facilities (IRFs) that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for calendar year (CY) 2021, which will affect their FY 2023 Annual Payment Update (APU). Non-compliance notifications were placed into facilities’ “Certification and Survey Provider Enhance Reports” (CASPER) folders in the Quality Improvement and Evaluation System (QIES) for hospice and skilled nursing facilities (SNFs), and into facilities’ “My Reports” folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs and long-term care hospitals (LTCHs). If a facility received a letter of non-compliance, it may submit a request for reconsideration to CMS via email. The submission deadline is 11:59 pm on August 11, 2022. View the full details and instructions for submission here.

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The Centers for Medicare and Medicaid Services (CMS) recently issued updates associated with the inpatient rehabilitation facility (IRF) provider preview reports and the IRF Patient Assessment Instrument (PAI).

CMS has released the updated IRF Provider Preview Reports, which contain provider performance scores for quality measures and contain IRF-PAI data submitted by IRFs from Quarter 1 (Q1) 2021 through Quarter 4 (Q4) 2021, as well as CDC Clostridium Difficile (CDI) and Catheter-Associated Urinary Tract Infections (CAUTI) measures from Quarter 4 (Q4) 2020 through Quarter 3 (Q3) 2021, and Q4 2018 through Q1 2019 of the Healthcare Personnel (HCP) Influenza measure. The new HCP COVID-19 Vaccination Coverage measure will also be publicly reported on Care Compare in the September 2022 release and will reflect Q4 2021 data. Unlike prior September Care Compare refreshes, CMS will not be preforming the annual update to IRF claims-based measures, due to CMS only resuming the reporting of claims-based measures during the June 2022 refresh.

Providers have until July 15, 2022, to review their performance data. Providers can request CMS review their data during the preview period if they believe the scores are inaccurate. The final reports will be published on Care Compare and Provider Data Catalog during the September 2022 refresh of the website. Additional information is on the CMS IRF Quality Reporting Program (QRP) public reporting website.

CMS also published the IRF-PAI Quarterly Questions & Answers (Q&A) document that provides clarification to existing guidelines.