IRF Count Down Continues: Part II

There’s an updated version of the IRF-PAI manual.

As we prepare for changes in how inpatient rehabilitation facilities (IRFs) are paid through the utilization of quality indicator data rather than Functional Independence Measure (FIMTM) scores to classify patients into appropriate case-mix groups (CMGs), it’s important that IRFs provide the most updated resources to key stakeholders within their organizations.

On April 30, the Centers for Medicare & Medicaid Services (CMS) posted the full version of the updated IRF Patient Assessment Instrument (IRF-PAI) Manual to its website. The file can be found in the downloads section of this link: IRF-PAI Manual 4-30-19. And if you’d like to review the most recent changes in the Manual, download the Change Table from that same location.

Noted updates to the Manual include the following:

  • Removal of all guidance related to FIMtm scoring.
  • The addition of an overview section to include information about Quality Reporting Program (QRP) indicators.
  • Restructuring of a number of sections to move key resource data to Appendix A: Impairment Group Codes and Associated ICD-10 Codes.
  • Provision of coding tips and instructions for when a patient becomes eligible for Medicare coverage or switches from Medicare fee-for-service (FFS) to Medicare Advantage (or from Medicare Advantage to FFS) during a stay.
  • The addition of coding tips for a number of the GG scoring items.

As IRFs approach the transition to the revised classification process, it is essential that key stakeholders train and retrain on accurate scoring.  

And don’t be fooled into thinking that we’ve been collecting this data for a few years now, so there’s no need to rethink our processes for collecting accurate data that reflects a true picture of patient deficits. Just as with the prior FIMtm scoring, failure to appropriately gauge patient deficits can result in significant revenue loss. Furthermore, while the proposed rule suggests that for most IRFs, the transition will be budget-neutral, the impact tables compare FY 2018 actual revenues with FY 2020 projected revenues. A closer comparison of FY 2019 projected revenues with projected FY 2020 revenues show a different perspective, with more IRFs likely to experience declines in overall revenue.

To review the projected impact on your organization, check out the impact tables posted with the Proposed Rule for FY 2020 online here: Impact Tables. While these tables may change with the Final Rule, IRFs should look at the trend from FY 2018 through FY 2020 in planning for the future.

We addressed these items as well as others that impact IRFs in our recent June 11, 2019, RACmonitor webinar: 2020 IRF PPS: Be Prepared for Less Work, More Risk. If you missed it, consider listening to the recorded version.

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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.

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