On July 31, 2019, the Centers for Medicare and Medicaid Services (CMS) released the final FY 2020 inpatient rehabilitation facility payment rule. This final rule also includes updates to the IRF Quality Reporting Program (QRP). Provisions of this final rule become effective October 1, 2019.

IRFs Will See Payment Increase of 2.5 Percent in FY 2020

Payments to inpatient rehabilitation facilities (IRFs) are based on a prospective payment system adjusted annually to account for the increased cost of goods and services. For 2020, CMS will base these costs on 2016 data, rather than the previous 2012 market basket data. As a result, CMS is finalizing a 2.9 percent (down from 3.0 percent in the proposed rule due to updated data) market basket increase, reduced by a 0.4 percent (0.5 percent in the proposed rule) productivity adjustment, for a total increase of 2.5 percent (the same as the proposed rule). CMS estimates that this will increase federal payments to IRFs by $210 million in FY 2020.

CMS Declines to Implement Proposed Weighted Motor Score for Assigning CAse-Mix Groups

Under the IRF prospective payment system, IRF patients are classified into case-mix groups (CMGs) which are weighted to reflect their relative resource usage. This classification is based, in part, on a motor score currently based on 19 data items, which are currently applied with equal weight on each item. For 2020, CMS proposed to weight these data with a particular emphasis on eating and toileting. However, due to extensive comments urging CMS to revert to the simpler unweighted system and what CMS claims is only a minor difference in scoring impact, the final rule does not implement this weighted scoring. CMS is also finalizing its proposal to eliminate one item (“GG0170A1 Roll left to right”) from the case mix score beginning in FY 2020.

As a result of the decision not to utilize a weighted case mix score, CMS’ data contractor amended the average lengths of stay of various conditions within the CMG system based on the latest two years of data.

PUBLICATION OF COMPLIANT IRF QUALITY REPORTING FACILITIES ENDS; NEW MEASURES ARE ADDED

CMS finalized its proposal to terminate the publication of a list of compliant IRFs on the IRF Quality Reporting Program (QRP) website beginning with the FY 2020 payment determination.

As part of CMS’ Meaningful Measures Initiative, two new measures regarding the transfer of health information will be added to the IRF QRP for discharges beginning October 1, 2020:

• Transfer of Health Information to the Provider–Post-Acute Care (PAC): this measure assesses whether a current reconciled medication list is given to a provider when a patient is discharged or transferred;
• Transfer of Health Information to the Patient–Post Acute Care (PAC): this measure assesses whether a current reconciled medication list is provided to the patient, family, or caregiver when the patient was discharged from a PAC setting.

CMS also modifies the specifications of the Discharge to Community- Post Acute Care (PAC) measure to exclude baseline nursing facility residents from the measure.

Beginning with the FY 2022 IRF QRP, IRFs are required to report standardized patient assessment data (SPADE), as required by the IMPACT Act. CMS had previously finalized SPADEs that included functional status, medical conditions, and comorbidities. In this final rule, CMS also finalizes the addition of a “Social Determinants of Health” category, requiring IRFs to collect data on race, ethnicity, health literacy, transportation, and social isolation. For the Preferred Language and Interpreter Services SPADE, CMS modifies its proposal to allow IRFs to submit this data with respect to admission rather than requiring submission for both admission and discharge.

Rule Includes RFI for IRF QRP Quality Measures, Measures Concepts, and SPADEs

CMS sought in its proposed rule general feedback on quality measures and measure concepts related to opioid use and frequency and the exchange of electronic health information and interoperability. In their responses, providers expressed concerns related to the unintended consequences of reporting opioid use, including under-prescribing or over-prescribing. Although CMS will not respond to these comments this year, the agency states they will use the stakeholder input for future rulemaking.

Definition of Rehab Physician Amended

CMS finalized the proposal to update the definition of rehabilitation physician to include that IRFs make the determination on qualification for a licensed physician to be designated a rehabilitation physician. Current regulation defines rehabilitation physician as “a licensed physician with specialized training and experience in inpatient rehabilitation.” Rather than specifying the level or type of training and experience required to be designated a rehabilitation physician, CMS clarifies that it is the IRFs’ responsibility to determine such qualifications.