On April 7, 2021, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2022. CMS proposes updates related to payment and the IRF Quality Reporting Program.
Comments on this proposed rule are due June 7, 2021.
Inpatient Rehabilitation Facilities to Get a $160m Increase in Payments
CMS proposes to update IRF payments overall by 2.2 percent, or an $160 million increase, in FY 2022. A 2-percentage point reduction will be applied to payments for IRFs that fail to meet quality data submission requirements. CMS states that although the Medicare Payment Advisory Commission (MedPAC) recommended a 5% reduction to the IRF payments, it does not have the authority to apply a different payment update than the adjusted market basket increase factor.
CMS proposes to continue to update the case-mix group (CMG) relative weights in a budget neutral manner and indicates that 97.3 percent of all IRF cases are in CMGs that will experience a less than 5 percent change. The methodology for calculating IRF outlier threshold amounts is to remain the same in FY 2022. The outlier threshold amount is to be updated from $ 7,906 for FY 2021 to $9,192 for FY 2022.
If finalized, these updates will be effective for discharges on and after October 1, 2021 to September 30, 2022.
CMS CONSIDERS MULTIPLE UPDATES TO THE IRF QUALITY REPORTING PROGRAM
For FY 2023, CMS proposes to calculate IRF QRP measures using three quarters (Q3 2020 through Q1 2021) of IRF QRP data for assessment-based measures, and six quarters for claims-based measures. During the COVID-19 public health emergency, CMS granted an exception to the IRF QRP reporting requirements for quarter 1 (January 1, 2020-March 31, 2020) and quarter 2 (April 1, 2020-June 30, 2020). Since this exception affected the standard number of quarters used to display QRP data, CMS updates the number of quarters it will use for public reporting.
COVID-19 Vaccination Coverage Data Submission Requirements
CMS proposes to adopt a COVID-19 Vaccine Coverage among health care providers measure beginning with the FY 2023 IRF QRP with initial data submission period from October 1, 2021 through December 31, 2022. Beginning fiscal year 2024, IRFs would be required to submit data for the entire calendar year. The Agency would make this data publicly available. This is consistent with a proposal to include such a measure in the inpatient psychiatric facility quality reporting program.
CMS Considers Future Quality Measures in Request for Information
CMS requests information on the importance, relevance, applicability, and appropriateness of quality measures in the table below. These measures are not under consideration for FY 2022, but CMS will use the information for future quality measure development efforts.
Future Measures and Measure Concepts Under Consideration for the IRF QRP
| Assessment-Based Quality Measures and Measure Concepts |
| Frailty |
| Opioid use and frequency |
| Patient reported outcomes |
| Shared decision-making process |
| Appropriate pain assessment and pain management processes |
| Health equity |
CMS Shows Effort to Address the Health Equity Gap in Request for Information
CMS requests information on following topics as part of its efforts to assess and address health equity[1] in post-acute care settings and for us in the IRFs QRP:
- Recommendations for quality measures or measurement domains that address health equity, for use in the IRF QRP.
- Guidance on any additional items, including standardized patient assessment data SPADEs, that could be used to assess health equity in the care of IRF patients, for use in the IRF QRP
- Recommendations for how CMS can promote health equity in outcomes among IRF patients
- Methods that commenters or their organizations use in employing data to reduce disparities and improve patient outcomes, including the source(s) of data used, as appropriate.
- The existing challenges providers encounter for effective capture, use, and exchange of health information, such as data on race, ethnicity, and other social determinants of health, to support care delivery and decision making.
A similar request was included in the proposed FY 2022 payment rule for inpatient psychiatric facilities, which was released simultaneously with the IRF proposed rule.
Fast Healthcare Interoperability Resources (FHIR) in Support of Digital Quality Measurement- Request for Information
Finally, CMS requests information on adopting a standardized definition of Digital Quality Measures (dQMs) across all quality programs. The proposed definition is, “Digital Quality Measures (dQMs) are quality measures that use one or more sources of health information that are captured and can be transmitted electronically via interoperable systems.”
CMS also request information on the potential development and implementation of a consistent portfolio of dQMs across quality programs (including the IRF QRP), agencies, and private payers. This would require alignment of measure concepts and the individual data elements used to build the measure specifications and calculate the measures.
[1] CMS uses the following definition from President Biden’s January 20, 2021 Executive Order to define health equity, “the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment, such as Black, Latino, and Indigenous and Native American persons, Asian Americans and Pacific Islanders and other persons of color; members of religious minorities; lesbian, gay, bisexual, transgender, and queer (LGBTQ+) persons; persons with disabilities; persons who live in rural areas; and persons otherwise adversely affected by persistent poverty or inequality.” https://www.govinfo.gov/content/pkg/FR-2021-01-25/pdf/2021-01753.pdf