Prospective Payment System (PPS) Final Rule

 

The Centers for Medicare & Medicaid Services (CMS) finalized its FY 2015 Inpatient Rehabilitation Facility (IRF) rule increasing payments 2.4% from Medicare, amounting to a $180 million increase from FY 2014. CMS also finalized its proposed freeze on facility-level adjustments for IRFs in FY 2015.

 

In Murer Consultant's estimation, the FY 2015 final rule does not represent a significant departure from the previous FY 2014 final rule. The key changes to the FY 2014 are indicated below:

 

60% Rule

 

Part of the program since its inception in 1983, IRFs are required to admit at least 60% of its patients from a grouping of one or more specific conditions in order to demonstrate that at least 60% of the IRF's patients require intensive rehab services. IRFs who fail to meet this presumptive compliance criteria will be excluded from the IRF-PPS rate and be paid at the lower inpatient PPS rate.

 

CMS delayed implementation of several proposed changes to the eligible diagnosis condition codes encompassed in the 60% rule to FY 2016. The proposed changes included:

• Remove 10 amputation related ICD-9 codes and 4 amputation and arthritis relative impairment group codes (IGC) from the presumptive compliance criteria

• Add therapy data collection and Arthritis Diagnosis Codes to the IRF-patient assessment instrument (IRF-PAI)

 The proposed changes will take effect in October 1, 2015.

 

IRF-Patient Assessment Instrument (PAI)

 

CMS also finalized proposed changes to IRF-PAI which includes a new Therapy Information Section that will require IRF providers to submit data regarding the amount and mode (i.e., individual, concurrent, group, and co-treatment) of therapy that patients are receiving and in which therapy discipline (PT, OT, speech/language) beginning October 1, 2015. The IRF-PAI form also revises the list of arthritis diagnosis and impairment group codes to indicate that prior treatment and severity requirements had been met for patients.

 

IRF Quality Reporting

 

CMS finalized two new measures for the IRF quality reporting program that are to impact FY 2017 payment - (1) Methicillin-resistant Staphylococcus aureus (MRSA) and Clostridium Difficile infections (CDI). Both measures are to be reported via the Centers for Disease Control's (CDC) National Healthcare Safety Network (NHSN). These changes are consistent with reporting requirements for long term acute care facilities and inpatient hospital facilities.

 

The final rule will take place on October 1, 2014.

 

We hope that this brief summary provides an overview of the complex regulations applicable to Inpatient Rehabilitation Facilities. For more information or to specifically discuss issues impacting your hospital, please contact Murer Consultants at 708-478-7030.