The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule for Inpatient Rehabilitation Facilities (IRFs) that would update payment policies for the 2024 fiscal year (FY), update IRF Quality Reporting Program (QRP) requirements, and modify the excluded unit regulation to allow hospitals to open a new IRF unit and begin getting paid under the IRF Prospective Payment System (PPS) at any time during the cost reporting period.
We have addressed the major components below:
Updates to Payment Rates
Following standard methodology, CMS has recommended a 3.7-percent increase in overall IRF payments, or an estimated $335 million increase in payments over the last FY. This increase is based on an update to the IRF PPS payment rates: a 3.0-percent rise, based on the proposed IRF market basket update of 3.2 percent, less a 0.2-percentage point multi-factor productivity (MFP) adjustment. This brings the proposed FY 2024 payment to $18,471.
Proposed Updates to Quality Reporting Program
CMS is also proposing to adopt two new measures, modify the measure related to healthcare personnel and the COVID-19 vaccine, remove three measures, and begin public reporting of the Transfer of Health Information to the Provider and the Patient.
Proposed New Measure, beginning with FY 2025 QRP: Discharge Function Score
This measure would assess the percentage of IRF patients who meet or exceed a calculated expected discharge function score. The expected score is calculated based on mobility and self-care items already collected by the organization on the IRF-PAI (Patient Assessment Instrument). The measure would replace the current measure related to the percentage of patients with an admission and discharge functional assessment and care plan, as noted below.
Proposed New Measure, beginning with FY 2026 QRP: COVID-19 Vaccine: Percent of Patients/Residents Who Are Up-to-Date
This measure looks at IRF patient stays where patients are up-to-date with recommended COVID-19 vaccinations, in accordance with the Centers for Disease Control and Prevention’s (CDC’s) most recent guidance. Collection of this data would be via a new standardized item on the IRF-PAI.
Modified Measure, beginning with FY 2026 QRP: COVID-19 Vaccine Coverage Among Healthcare Personnel
The modification in this measure would include what percentage of healthcare personnel (HCP) in IRFs who are considered to be up-to-date with recommended COVID-19 vaccination, in accordance with the CDC’s most recent guidance. Previously, IRFs reported only on whether HCPs had received the primary vaccination series for COVID-19. The modification would require IRFs to report the cumulative number of HCP who are up-to-date with recommended COVID-19 vaccinations in accordance with the CDC’s most recent guidance.
Removal of Three Measures, beginning with FY 2025 QRP: Functional Outcomes Measures
CMS proposes to remove the following functional outcomes measures:
- The Application of Functional Assessment/Care Plan Measure; and
- The IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients
The performance level for these measures is so high and so consistent that they are no longer meaningful, and/or they are similar to other measures.
The IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients
Here, the costs of the measure outweigh the benefits, and the measure is similar to or duplicative of other measures within the data collection set.
Public Reporting of Quality Measures – beginning with the September 2024 Care Compare Refresh, or sooner, if possible – Report Transfer of Health Information to the Provider and the Transfer of Health Information to the Patient
This data is currently being collected and would be added to the public reporting data set. The measures report the percentage of patient stays with a discharge assessment indicating that a current reconciled medication list was provided to the subsequent provider, or to patients or their families or caregivers at discharge or transfer.
Comments
Industry response is essential, related to the key requests for information outlined by CMS in the proposed rule. Comments must be received by 5 p.m. on June 2, and submitted either electronically or by mail.
Review the proposed rule here: Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2024 and Updates to the IRF Quality Reporting Program
Review the CMS fact sheet here: Fiscal Year 2024 Inpatient Rehabilitation Facility Prospective Payment System Proposed Rule (CMS-1781-P)
