FY 2020 Final Rule, Not Final

Some proposed IRF provisions were not finalized.

On July 31, 2019, the Centers for Medicare & Medicaid Services (CMS) issued the final rule for the inpatient rehabilitation facility prospective payment system for the fiscal year 2020. The proposed rule is on display for review at this link:  IRF FY 2020 Final – Review Copy and is expected to be published in the Federal Register on August 8, 2019.

In general, the final rule closely matches the proposed rule, but it is noteworthy that several provisions including the weighting of the motor score for CMG placement and the requirement to submit Quality Indicator data for all patients regardless of payer were not finalized.

Updates Impacting Payment

The proposal includes an estimated overall 2.5 percent increase factor that includes an IRF-specific market basket estimate of 2.9 percent less a .4 percent productivity adjustment for an overall increase in payment of $210 million dollars.

Case Mix Group Revisions (Using FY 2017 and FY 2018 data)

Of note, CMS reversed the proposed use of a weighted motor score to assign patients to CMS and finalized the use of an unweighted motor score for CMG placement based on the rationale that this would allow providers an easier transition to use of Quality Indicator data for payment purposes. The final Motor Score Weight Index will include 18 items noted in Table 2 from the rule, which is reproduced below, and all will have equal weight in the calculation of the Motor Score for placement in the CMG tables.

The Case-Mix Group Revisions based on the removal of FIM scoring and use of Quality Indicator data for classification of patients into CMG groups were finalized including updates to CMG Relative Weights and Average Length of Stay Values.

Updates Related to Quality Measures

The rule finalized two additional Quality Measures both of which relate to Medication Reconciliation.  Both of these Quality Measures would assess whether the IRF provides a reconciled medication list at the time of transfer or discharge and are adopted beginning with FY 2022 IRF Quality Reporting Requirements.  The requirements are for the following:

• Transfer of Health Information to the Provider; and
• Transfer of Health Information to the Patient.

Standardized Patient Assessment Data Elements (SPADEs)

The proposed standardized patient assessment data elements (SPADEs) were adopted.  As noted in our earlier articles, these added data elements will assess cognitive function and mental status, special services, treatments and interventions, medical conditions and comorbidities, impairments, and social determinants of health (race and ethnicity, preferred language and interpreter services, health literacy, transportation, or social isolation).

Additional Finalized Provisions

A number of additional provisions included in the proposed rule were finalized.  These include the following:

• Updates to the Discharge to Community IRF QRP measure to exclude baseline nursing home residents from the calculation;
• Removal of the published list of compliant IRFs from the IRF QRP website; and,
• Clarification that the determination as to whether a physician qualifies as a rehabilitation physician is to be determined by the IRF.

Additional Provisions not Finalized

In addition to the determination NOT to weight Motor Scores for CMG placement, CMS also decided NOT to finalize the provision that would require IRFs to collect IRF-PAI data on all patients regardless of the patients’ payer