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CMS Issues FFY 2020 Inpatient Rehabilitation Facility PPS Proposed Rule

For CEOs, CFOs, Directors of Rehabilitation Services

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The Centers for Medicare & Medicaid Services (CMS) has issued the proposed rule for the inpatient rehabilitation facility prospective payment system (IRF PPS) for federal fiscal year (FFY) 2020. If finalized, the provisions would be effective Oct. 1, 2020.

CHA is reviewing the proposed rule and will issue a summary in the coming weeks, along with information on an upcoming member forum to review the proposed rule’s provisions and develop comments, which are due June 17. 

Below are highlights of the current proposed rule.  

Implementation of Standardized Patient Assessment Data Elements (SPADEs)
Among CMS’ most notable proposals is a requirement that IRFs report standardized patient assessment data elements (SPADEs) beginning Oct. 1, 2020. While some of the proposed SPADEs, which will be used to assess patient status at admission and discharge, are already collected via the IRF Patient Assessment Instrument (IRF-PAI), the current proposal would add many more. CMS also proposes to add a new domain with seven new data elements related to social determinants of health. 

Payment Provisions
CMS proposes to increase net payments by 2.3 percent, or $195 million, as compared to FFY 2019, the result of a 3 percent market-basket update, offset by a statutorily mandated cut for productivity. The update also reflects a proposed market basket rebasing. Under the current proposal, the outlier threshold would increase from the current $9,402 to $9,935.    

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 and instead incorporating similar data elements contained in Section GG of the IRF-PAI to assign patients to a payment category, or case-mix group. CMS has updated its recalibration of the case-mix classification system, which will be implemented in a budget-neutral manner using two years of data. 

Quality Reporting
CMS proposes to adopt two new process measures to the IRF Quality Reporting Program (QRP), addressing the “Transfer of Health Information” domain as required by the Improving Medicare Post-Acute Care Transformation Act. Data collection on these measures would begin on Oct. 1, 2020, and the measures would be incorporated into the IRF QRP in FFY 2022. CMS also proposes to modify the existing “Discharge to Community” measure to exclude IRF patients who were admitted from long-term nursing facility stays, and to begin public display on the IRF Compare website of the “Drug Regimen Review Conducted with Follow up for Identified Issues” measure in calendar year 2020. 

CMS also proposes to expand the reporting of IRF-PAI data used for the IRF QRP to include all patients, regardless of payer source, beginning Oct. 1, 2020. 

Additional information is available in CMS’ proposed rule fact sheet.