On April 17, 2019, the Centers for Medicare and Medicaid Services (CMS) released the proposed FY 2020 inpatient rehabilitation facility payment rule. This proposed rule also includes updates to the IRF Quality Reporting Program (QRP). Comments on the proposed rule are due on June 17, 2019.

IRFs Could 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 proposes to base these costs on 2016 data, rather than the current 2012 market basket data. As a result, CMS proposes a 3.0 percent market basket increase, reduced by a 0.5 percent productivity adjustment, for a total increase of 2.5 percent. CMS estimates that this will increase federal payments to IRFs by $195 million in FY 2020.

CMS Emphasizes Eating and Toileting in 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 based on 19 data items, which are currently applied with equal weight on each item. For 2020, CMS proposes to weight these data items as follows:

CMS is also proposing to amend the relative weights and average lengths of stay of various conditions within the CMG system based on the latest data.

CMS Proposes Ending Publication of Compliant IRF Quality Reporting Program Facilities and Inclusion of Two New Measures for FY 2022

Beginning with the FY 2020 payment determination, CMS is proposing to no longer publish a list of compliant IRFs on the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) website after receiving feedback from stakeholders that this list offers minimal benefit.

To comply with the IMPACT Act, CMS is proposing to adopt two process measures for the IRF QRP that are in the quality measure domain on the communication of health information and care preferences to an individual or caregiver when transition from a post-acute care (PAC) provider to another applicable setting.  The following two measures are being proposed for adopting beginning with the 2022 IRF QRP:

• 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 believe that these measures are in line with the agency’s overall priority of promoting effective communication and care coordination as part of the Meaningful Measures initiative. The agency is also proposing to update the specifications of the Discharge to Community- Post Acute Care (PAC) measure to exclude baseline nursing facility residents from the measure.

Also beginning with FY 2022, IRFs will be required to report standardized patient assessment data (SPADE), as required by statute. CMS previously finalized that SPADEs will include functional status and medical conditions and comorbidities. In this proposed rule, CMS is now proposing that IRFs also report admission and discharge data. In addition, the agency is proposing to create a new SPADE category, Social Determinants of Health.

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

CMS is seeking general feedback on the following quality measures and measure concepts: opioid use and frequency and the exchange of electronic health information and interoperability. The agency is also seeking feedback on the following standardized patient assessment data elements (SPADEs): cognitive complexity; dementia; bladder and bowel continence; care preferences, advance care directives, and goals of care; caregiver status; veteran status; health disparities and risk factors; and sexual orientation.

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 to be Amended

Current regulation defines rehabilitation physician as “a licensed physician with specialized training and experience in inpatient rehabilitation.” CMS proposes to revise this definition to add that IRFs make the determination on whether a physician is qualified to be a rehabilitation physician. While CMS chooses not to specify the level of training and experience required for rehabilitation physicians, the agency is seeking comments on the proposed definition.