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.

 AngiePhillips 080519

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

Facebook
Twitter
LinkedIn

Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

Related Stories

Defining High-Quality Documentation

Defining High-Quality Documentation

Last week I wrote about the importance of defining what clinical documentation is, within the scope of clinical documentation integrity (CDI) reviews. This week, I’ll

Read More

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

The Cost of Ignoring Risk Adjustment: How HCCs Impact Revenue & Compliance

The Cost of Ignoring Risk Adjustment: How HCCs Impact Revenue & Compliance

Stop revenue leakage and boost hospital performance by mastering risk adjustment and HCCs. This essential webcast with expert Cheryl Ericson, RN, MS, CCDS, CDIP, will reveal how inaccurate patient acuity documentation leads to lost reimbursements through penalties from poor quality scores. Learn the critical differences between HCCs and traditional CCs/MCCs, adapt your CDI workflows, and ensure accurate payments in Medicare Advantage and value-based care models. Perfect for HIM leaders, coders, and CDI professionals.  Don’t miss this chance to protect your hospital’s revenue and reputation!

May 29, 2025
I050825

Mastering ICD-10-CM Coding for Diabetes and it’s Complications: Avoiding Denials & Ensuring Compliance

Struggling with ICD-10-CM coding for diabetes and complications? This expert-led webcast clarifies complex combination codes, documentation gaps, and sequencing rules to reduce denials and ensure compliance. Dr. Angela Comfort will provide actionable strategies to accurately link diabetes to complications, improve provider documentation, and optimize reimbursement—helping coders, CDI specialists, and HIM leaders minimize audit risks and strengthen revenue integrity. Don’t miss this chance to master diabetes coding with real-world case studies, key takeaways, and live Q&A!

May 8, 2025
2025 Coding Clinic Webcast Series

2025 ICD-10-CM/PCS Coding Clinic Update Webcast Series

Uncover critical guidance. HIM coding expert, Kay Piper, RHIA, CDIP, CCS, provides an interactive review on important information in each of the AHA’s 2025 ICD-10-CM/PCS Quarterly Coding Clinics in easy-to-access on-demand webcasts, available shortly after each official publication.

April 14, 2025

Trending News

Featured Webcasts

The Two-Midnight Rule: New Challenges, Proven Strategies

The Two-Midnight Rule: New Challenges, Proven Strategies

RACmonitor is proud to welcome back Dr. Ronald Hirsch, one of his most requested webcasts. In this highly anticipated session, Dr. Hirsch will break down the complex Two Midnight Rule Medicare regulations, translating them into clear, actionable guidance. He’ll walk you through the basics of the rule, offer expert interpretation, and apply the rule to real-world clinical scenarios—so you leave with greater clarity, confidence, and the tools to ensure compliance.

June 19, 2025
Open Door Forum Webcast Series

Open Door Forum Webcast Series

Bring your questions and join the conversation during this open forum series, live every Wednesday at 10 a.m. EST from June 11–July 30. Hosted by Chuck Buck, these fast-paced 30-minute sessions connect you directly with top healthcare experts tackling today’s most urgent compliance and policy issues.

June 11, 2025
Open Door Forum: The Changing Face of Addiction: Coding, Compliance & Care

Open Door Forum: The Changing Face of Addiction: Coding, Compliance & Care

Substance abuse is everywhere. It’s a complicated diagnosis with wide-ranging implications well beyond acute care. The face of addiction continues to change so it’s important to remember not just the addict but the spectrum of extended victims and the other social determinants and legal ramifications. Join John K. Hall, MD, JD, MBA, FCLM, FRCPC, for a critical Q&A on navigating substance abuse in 2025.  Register today and be a part of the conversation!

July 16, 2025

Trending News

Prepare for the 2025 CMS IPPS Final Rule with ICD10monitor’s IPPSPalooza! Click HERE to learn more

Get 15% OFF on all educational webcasts at ICD10monitor with code JULYFOURTH24 until July 4, 2024—start learning today!

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24