Health Reform WK-EDGE CMS proposes $75M increase for IRF reimbursement in FY 2019
Wednesday, May 16, 2018

CMS proposes $75M increase for IRF reimbursement in FY 2019

By Sheila Lynch-Afryl, J.D., M.A.

Inpatient rehabilitation facilities (IRFs) would see an increase of 0.9 percent, or $75 million, in their reimbursement for fiscal year (FY) 2019 under the FY 2019 IRF prospective payment system (PPS) Proposed rule. CMS also proposed to update IRF coverage requirements and measures under the IRF Quality Reporting Program (QRP) (Proposed rule, 83 FR 20972, May 8, 2018).

Payment update. CMS proposed, pursuant to Soc. Sec. Act §1886(j)(3)(C), a FY 2019 IRF update of 1.35 percent (2.9-percent market basket update, less 0.8-percentage point productivity adjustment mandated by Sec. 3401(d) of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148), less an additional ACA-required reduction of 0.75-percentage point). The proposed $75 million dollar increase would be the same as the IRF PPS increase finalized for FY 2018 (see $75M increase for IRFs in FY 2018, August 1, 2018). While the Medicare Payment Advisory Commission (MedPAC) recommended a 5-percent reduction in IRF PPS payment rates for FY 2019 (see Move beyond MIPS, MedPAC tells Congress, March 20, 2018), CMS noted that it lacks the statutory authority to apply a different update.

CMS would also update the outlier threshold amount from $8,679 for FY 2018 to $10,509 for FY 2019 to maintain estimated outlier payments at approximately 3 percent of total estimated aggregate IRF payments for FY 2019.

Coverage requirements. IRF care is considered by Medicare to be reasonable and necessary under Soc. Sec. Act §1862(a)(1) only if the patient meets all of the IRF coverage requirements outlined in 42 C.F.R. Sec. 412.622(a)(3), (4), and (5). CMS proposed to amend: (1) §412.622(a)(3)(iv) to provide that the post-admission physician evaluation required under subsection (a)(4)(ii) may count as one of the face-to-face physician visits required under §412.622(a)(3)(iv) beginning with FY 2019; and (2) 42 C.F.R. §412.622(a)(5)(A) to provide that the rehabilitation physician may lead the interdisciplinary meeting remotely without any additional documentation requirements.

In addition, CMS sought public comments on whether: (1) the rehabilitation physician should have the flexibility to determine that some of the IRF visits can be appropriately conducted remotely via another mode of communication, such as video or telephone conferencing; and (2) potentially allowing IRFs to expand their use of non-physician practitioners to fulfill some of the requirements that rehabilitation physicians are currently required to complete.

The Proposed rule would also remove 42 C.F.R. §412.606(a) since IRFs are already required to fulfill this requirement under §§482.12(c)482.24(c), and 412.3.

IRF QRP. CMS proposed to remove two measures from the IRF QRP measure set, as created pursuant to ACA Sec. 3004(b): National Healthcare Safety Network (NHSN) Facility-wide Inpatient Hospital-onset Methicillin-resistant Staphylococcus aureus (MRSA) Bacteremia Outcome Measure (NQF #1716), beginning with the FY 2020 IRF QRP, and Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680), beginning with the FY 2021 IRF QRP.

The Proposed rule would adopt an additional factor to consider when evaluating measures for removal from the IRF QRP measure set: Factor 8, the costs associated with a measure outweigh the benefit of its continued use in the program. CMS would remove measures based on this factor on a case-by-case basis. In addition, under the Proposed rule, 42 C.F.R. §412.634(d)(1) would be amended to expand the methods by which CMS can notify an IRF of non-compliance with IRF QRP requirements.

IRF-PAI. Through the IRF Patient Assessment Instrument (IRF-PAI), IRFs are required to collect and electronically submit patient data for Medicare Part A and Part C beneficiaries. Because data collected for the IRF QRP overlaps with the FIM™ instrument and associated Function Modifiers, CMS proposed to remove the FIM™ instrument and associated Function Modifiers from the IRF-PAI beginning with FY 2020.

Request for information. CMS also sought public feedback on how best to accomplish the goal of fully interoperable health IT and electronic health record (EHR) systems for Medicare- and Medicaid-participating providers and suppliers.

FederalRegisterIssuances: ProposedRules NewsFeed AgencyNews InpatientFacilityNews MedicarePartANews MedicarePartCNews MedicaidNews QualityNews

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