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CMS Issues FFY 2020 Inpatient Rehabilitation Facility PPS Final Rule

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The Centers for Medicare & Medicaid Services (CMS) has issued the final rule for the inpatient rehabilitation facility prospective payment system (IRF PPS) for federal fiscal year (FFY) 2020. The provisions will be effective Oct. 1, 2020. According to CMS, this final rule represents continued movement toward the eventual transition to a unified post-acute care (PAC) PPS. 

Below are highlights of the final rule.  

Payment Impact
As provided in the FFY 2019 final rule, CMS will reform the current IRF patient assessment and case-mix  process by discontinuing the use of the functional independence measure (FIM), and instead incorporating similar data elements contained in Section GG of the IRF patient assessment instrument (IRF-PAI) for the purpose of assigning patients to a payment category, or case-mix group (CMG).  Notably, in response to comments, CMS opts not to adopt a weighted motor score for CMG calculation.  

The final rule updates the CMG relative weights and average length of stay values, and uses concurrent inpatient prospective payment system (IPPS) wage index data to align wage index data across settings of care.  Overall, CMS projects that payments to IRFs will increase by 2.5%, or $210 million, as compared to FFY 2019, the result of a 2.9% market basket update, offset by statutorily mandated 0.4% cut for productivity. 

Quality Reporting/SPADEs
CMS finalizes several proposals relating to the IRF Quality Reporting Program (QRP), including the addition of several standardized patient assessment data elements (SPADEs), several of which address social determinants of health. CMS also finalizes two new measures on transfer of health information, as well as a change to the existing “Discharge to Community” measure to exclude baseline nursing home residents. In response to comments, CMS does not finalize its proposal to collect IRF QRP data on all patients regardless of payer source.