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Medical Rehab

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An RCPA Info was issued on August 18, 2016 regarding a project that was announced by the Centers for Medicare and Medicaid Services (CMS) specific to the development and maintenance of a post-acute care (PAC) cross-setting standardized assessment data. Originally, the comment deadline on this project was set for August 26, 2016. Due to concerns voiced to CMS regarding a two-week comment period, the deadline has now changed. The comment period on this project has now been extended to Monday, September 12, 2016.

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On August 15, 2016, the Centers for Medicare and Medicaid Services (CMS) posted to their public comment page, Development and Maintenance of Post-Acute Care (PAC) Cross-Setting Standardized Assessment Data, with a request for comment deadline of August 26, 2016.

This project involves CMS contracting with RAND to develop standardized assessment-based data items to meet the requirements as set forth under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, Section 2(a). Development of standardized data items includes conducting environmental scans of the evidence, data item conceptualization, drafting data item specifications, convening technical expert panels, and feasibility piloting.

The Centers for Medicare & Medicaid Services (CMS) seeks comments from stakeholders on data items that meet the IMPACT Act domains of: cognitive function and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; and impairments. In addition to general comments, CMS is specifically interested in public feedback regarding the topics below:

  • Potential for improving quality: includes consideration of the data element’s ability to improve care transitions through meaningful exchange of data between providers; improve person-centered care and care planning; be used for quality comparisons; and support clinical decision-making and care coordination;
  • Validity: includes consideration of the data element’s proven or likely inter-rater reliability (i.e., consensus in ratings by two or more assessors) and validity (i.e., whether it captures the patient attribute being assessed);
  • Feasibility for use in PAC: includes consideration of the data element’s potential to be standardized and made interoperable across settings; clinical appropriateness; and relevance to the work flow across settings; and
  • Utility for describing case mix: includes whether the data element could be used with different payment models, and whether it measures differences in patient severity levels related to resource needs.

Comments may be submitted on the entire set of data elements or specific to individual data elements and should be sent via email or to:

RAND Corporation
1200 South Hayes Street
Arlington, VA 22202-5050
Attn: Barbara Hennessey, W7E

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The Department of Human Services (DHS) has just issued a Medical Assistance (MA) Bulletin for providers relating to Act 62 titled, Payment of Claims for Services Provided to Children and Adolescents for the Diagnostic Assessment and Treatment of Autism Spectrum Disorder (ASD). The purpose of this bulletin is to remind providers enrolled in the MA Program, both fee-for-service (FFS) and HealthChoices, of the requirement to bill a child’s or adolescent’s private health insurance company before submitting a claim for the diagnostic assessment or treatment of ASD. It is also to inform providers of the diagnosis codes and procedure codes which will be included in the MA FFS cost avoidance process, effective Friday, September 30. HealthChoices managed care organizations will provide guidance and information to contracted practitioners and providers in the Medicaid managed care system with regard to implementation by September 30.

The DHS clinical staff has identified behavioral health, physical health, and rehabilitation procedure codes that reflect services for the diagnostic assessment and treatment of ASD covered under Act 62. The procedure codes that are on the MA Program fee schedule will be subject to the cost avoidance process for MA FFS claims beginning September 30.

Registration is open now for two webinar sessions on Thursday, August 25 that are being held by DHS in collaboration with RCPA:

  • Session 1, 12:00–1:00 pm: The target audience for this webinar session is BH-MCOs, counties, and county oversight organizations.
  • Session 2, 1:00–2:00 pm: The target audience for this webinar session is behavioral health and pediatric rehabilitation provider organizations.

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The Centers for Medicare and Medicaid Services (CMS) will be hosting a webinar on Tuesday, August 23, 2016, 1:30 – 3:00 pm EDT focusing on the preview reports for inpatient rehabilitation facilities (IRFs) and also long-term care hospitals (LTCHs) that will be made available to providers soon. During the webinar, CMS will review how to access the reports, how to interpret the content of the reports, and what to do if providers feel their reports contain an error. To participate in the webinar, registration is required.

Additional information is available on the IRF Quality Reporting Training web page. Questions regarding the webinar should be directed to the IRF Quality Reporting web desk.

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RCPA members are reminded to consider soliciting nominations for a Technical Expert Panel (TEP) that will provide input on two new quality measures in development for post-acute care providers (including inpatient rehabilitation facilities, skilled nursing facilities, long-term care hospitals, and home health agencies).

The Centers for Medicare & Medicaid Services (CMS) has contracted with RTI International and Abt Associates to develop and refine a cross-setting, post-acute care transfer of health information and care preferences quality measure as required by the Improving Medicare Post-Acute Care Transformation Act of 2014. The two new quality measures include:

  • Transfer of Information at Post-acute Care Admission, Start, or Resumption of Care from Other Providers/Settings; and
  • Transfer of Information at Post-acute Care Discharge or End of Care to Other Providers/Settings.

In alignment with the CMS and National Quality Strategy objectives and goals, the purpose of this project is to develop, maintain, re-evaluate, and implement measures that will drive high quality in post-acute care through CMS’ quality reporting programs. This includes the inpatient rehabilitation facility, skilled nursing facility, long-term care hospital, and home health quality reporting programs.

CMS is seeking technical experts with expertise in care transitions and information transfer during transitions, admission and discharge planning, and care coordination, among other areas of knowledge. The call for technical expert panel members is open through August 21, 2016.

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The Centers for Medicare and Medicaid Services (CMS) will be conducting a two-day inpatient rehabilitation facility (IRF) quality reporting program (QRP) training event on Tuesday, August 9 & Wednesday, August 10 in Chicago, IL. For members that can’t attend the training in person, a live webcast will be available (Note: the title of the event on this page hosting the webcast will not be updated until August 9).

  • On August 9, the training will be conducted from 9:00 am to 6:00 pm EDT.
  • On August 10, the training will be conducted from 9:00 am to 3:30 pm EDT.

The focus of this training event will be to provide IRFs with assessment-based data collection instructions and updates associated with the changes in the October 1, 2016 release of the IRF-Patient Assessment Instrument (PAI) version 1.4 and other reporting requirements of the IRF QRP.

The training materials are now available under the Downloads section of CMS’ IRF Quality Reporting Training web page. If members have questions or need additional information about the logistics of the training session, please email CMS’ PAC Training mailbox.

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The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2017 inpatient rehabilitation facility (IRF) prospective payment system (PPS) final rule in today’s Federal Register.

The majority of the final rule focuses on changes in the IRF Quality Reporting Program (QRP), pursuant primarily to the requirements of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. The rule continues to address implementation of the IMPACT Act requirements regarding resource use and quality measures, adding five new measures to the IRF QRP. Four measures will begin October 1, 2016, and are collected from Medicare claims data, so no additional reporting action from providers is required. These four measures include:

  • Discharge to Community – Post-Acute Care (PAC) IRF QRP (claims-based);
  • Medicare Spending Per Beneficiary (MSPB) – PAC IRF QRP (claims-based);
  • Potentially Preventable 30 Day Post-Discharge Readmission Measure for IRFs (claims-based); and
  • Potentially Preventable Within Stay Readmission Measure for IRFs (claims-based).

The remaining measure, Drug Regimen Review Conducted with Follow-up for Identified Issues, will begin October 1, 2018, and will require additional items on the IRF Patient Assessment Instrument (IRF PAI).

Other key provisions included in the final rule:

Standard Payment Rate
The standard payment rate conversion factor will increase in FY 2017 to $15,708, compared to the proposed amount of $15,674. This amount is the result of a 2.7 percent rehabilitation-specific market basket increase, minus a productivity adjustment of 0.3 percent and a 0.75 percent ACA adjustment. The FY 2016 standard payment rate conversion factor was $15,478.

CMS used the rehabilitation market basket for the first time. It was adopted last year. The standard payment update also accounts for budget neutrality factors for the wage index and labor related share of 0.9992 and for the CMG weight revisions of 0.9992 plus changes to the outlier threshold. Table 5 in the rule (not reproduced here) displays the FY 2017 payment rates.

Update to the CMG Weights, Lengths of Stay, and Comorbidities
CMS updated the Case Mix Group (CMG) weights using FY 2014 cost report data and the FY 2015 claims data as well as the average lengths of stay (ALOS) per CMG. Approximately 99.5 percent of the cases affected by the change in weights would be changed by less than 5 percent.

Outlier Threshold
CMS updates the outlier threshold amount to $7,984 from $8,658 for FY 2016 in order to maintain the outlier payments at three percent of total IRF payments in FY 2017. The national cost-to-charge ratio ceiling for FY 2017 is 1.29; the ceiling for rural IRFs is 0.522 and 0.421 for urban IRFs.

ICD-10-CM Presumptive Compliance Coding Changes
Unfortunately, CMS did not address the problems with the ICD-10-CM codes which eliminated certain key diagnoses from being allowed for consideration in calculating a provider’s presumptive compliance in meeting the 60 percent rule. The largest set of affected codes fall into the area of brain injury under IGCs 2.21 and 2.22.

CMS did, however, comment that IRFs are permitted to use “D” as an eligible seventh character for traumatic brain injury diagnosis codes on both the claim and the IRF PAI. However, for the reasons indicated in the FY 2015 IRF PPS final rule effective with discharges occurring on or after October 1, 2015, ICD-10-CM codes with the seventh character extension of “D” are not included in the ICD-10-CM versions of the “List of Comorbidities,” “ICD-10-CM Codes That Meet Presumptive Compliance Criteria,” or “Impairment Group Codes That Meet Presumptive Compliance Criteria.”

The payment changes to the rule will apply to IRF discharges on or after October 1, 2016 and before September 30, 2017. The quality reporting requirements are effective for discharges on or after October 1, 2106.

A more complete analysis of the rule will be forthcoming and reviewed/discussed extensively at the upcoming RCPA Outpatient Rehabilitation Committee meeting on Thursday, August 18, 2016, and the Medical Rehab Committee meeting on Thursday, September 8, 2016.

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On July 19, 2016, the Office of Inspector General (OIG) for the US Department of Health and Human Services (HHS) issued a report, Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries, part of a series on adverse events in health care settings or harm resulting from medical care. This report cites that incidence of these events in rehabilitation hospitals is similar to that of acute care hospitals and skilled nursing facilities that has been reported in previous OIG findings. The findings from this report resulted from the review of a national sample of medical records from 417 Medicare beneficiaries discharged from rehab hospitals in March 2012.

The OIG recommended that the Centers for Medicare and Medicaid Services (CMS) and the Agency for Healthcare Research and Quality (AHRQ) raise awareness of patient safety issues in rehabilitation hospitals and other health care settings. CMS and AHRQ concurred with the OIG recommendations.

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The Centers for Medicare and Medicaid Services (CMS) published a proposed rule in the August 2, 2016 Federal Register that proposes to implement three new Medicare Parts A and B episode payment models under section 1115A of the Social Security Act, which are meant to improve quality and lower cost. The proposed rule includes a new mandatory bundled payment model for cardiac care in 98 geographical markets for patients who have a heart attack or undergo bypass surgery. The rule would also extend the existing bundled payment model for hip and knee replacements – the Comprehensive Care for Joint Replacement model – to include hip and femur surgeries. Also proposed are new incentive payments designed to increase the use of cardiac rehabilitation. Additionally, new pathways are outlined for physicians participating in bundled payment models to qualify for payment incentives under the proposed Quality Payment Program, which implements the Medicare Access and CHIP Reauthorization Act (MACRA). CMS issued a fact sheet to provide more detailed information on the key provisions of this proposed rule. Comments are due by October 3, 2016.

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