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CHA Provides Comments on IRF PPS, SNF Proposed Rules for FFY 2020

For CFOs, Reimbursement Staff, Quality Reporting Leaders, Post-Acute Care Leaders, Government Relations Staff

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CHA has submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) federal fiscal year (FFY) 2020 proposed rules for the prospective payment systems (PPS) for inpatient rehabilitation facilities (IRFs) and skilled-nursing facilities (SNFs). 

In its letters, CHA expresses concern about the scale and impact of changes in post-acute settings, including IRF and SNF, over the past several years, and encourages CMS to monitor the impact of ongoing case-mix methodology changes on facility operations and patient access. CHA also comments on CMS’ proposals to add multiple new standardized patient assessment data elements (SPADEs) to the IRF patient assessment instrument and the minimum data set, and recommends that CMS:

  • Reduce the speed and scope of SPADE implementation.
  • Create a transparent data analysis plan.
  • Develop a framework for prioritization of SPADEs.
  • Adopt a staged implementation plan. 

Each comment letter also addresses the effect of proposed changes in the adjusted area wage index on post-acute care providers in California.