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Medical Rehab

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The Centers for Medicare and Medicaid Services (CMS) released and published the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule in the August 6, 2024, Federal Register. Some of the key provisions contained in the provider rule are noted below.

Payment Updates

CMS estimates aggregate payments to IRFs will increase by 2.8 percent in FY 2025, compared to the 4.0 percent payment update that CMS finalized for FY 2024. This update is the result of an annual market basket update, reduced by a productivity adjustment, budget neutrality adjustments for changes to CMG weights and labor/wage changes, and adjustments to the outlier case threshold.

As in previous years, CMS will adopt new delineations for the Core-Based Statistical Areas (CBSA) as identified by the Office of Management and Budget (OMB). [Additional and more detailed information on these new CBSAs can be found in OMB Bulletin No. 23-01] These changes will result in certain counties being reclassified from urban to rural and vice-versa, as well as some counties shifting to different CBSAs. As a result, CMS projects that approximately 10 percent of providers will have a higher wage index, but 16 percent will face a decrease in wage index values (primarily for those reclassified as urban, thus losing the rural adjustment). Thus, CMS finalized a transitional “phase-out” policy for those negatively impacted, such that IRFs set to lose their rural adjustment will retain two-thirds of the adjustment in FY 2025, one-third of the adjustment in FY 2026, and fully “lose” the rural adjustment in FY 2027. CMS estimates that 8 IRFs would be reclassified as urban and thus lose the 14.9 percent rural adjustment.

CMS increased the outlier threshold amount from $10,423 for FY 2024 to $12,043 for FY 2025 (slightly lower than the proposed rule’s projection). This change will account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.

Quality Reporting Program (QRP) Updates

CMS finalized its proposal to adopt four new items as Standardized Patient Assessment Data Elements (SPADE) under the social determinants of health (SDOH) category beginning with the FY 2028 IRF QRP: one Living Situation item; two Food items; and one Utilities item. CMS notes that these new SPADES are intended to assist IRFs in “better addressing those identified needs with the patient, their caregivers, and community partners during the discharge planning process, if indicated.”

Transportation Item Modification Finalized Beginning with the FY 2028 IRF QRP (October 1, 2026 Implementation)

Consistent with the AHC HRSN Screening Tool, CMS finalized a proposal to modify the A1250. Transportation item currently collected in the IRF–PAI in two ways: (1) revise the look-back period for when the patient experienced lack of reliable transportation; and (2) simplify the response options.

  • A1250. Transportation currently collected in the IRF-PAI asks: “Has lack of transportation kept you from medical appointments, meetings, work, or from getting things needed for daily living?” The response options are: (A) Yes, it has kept me from medical appointments or from getting my medications; (B) Yes, it has kept me from non-medical meetings, appointments, work, or from getting things that I need; (C) No; (X) Patient unable to respond; and (Y) Patient declines to respond.
  • The finalized Transportation item asks, “In the past 12 months, has a lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?” The final response options are: (0) Yes; (1) No; (7) Patient declines to respond; and (8) Patient unable to respond.

Finalized Proposal to Remove the Admission Class Item From the IRF-PAI Beginning October 1, 2026, with Minor Modification

  • CMS asserts that the Admission Class Item is currently not used in the calculation of quality measures already adopted in the IRF QRP. It further notes that it is not used for previously established purposes unrelated to the IRF QRP, such as payment, survey, or care planning. This removal will be effective beginning with the FY 2028 IRF QRP (beginning with patients admitted on October 1, 2026); however, IRFs will not be required to collect this item beginning with patients admitted on October 1, 2024.

For additional information, CMS published a fact sheet that provides an overview of the provisions contained in the final rule.

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In accordance with DHS rebranding and the Governor’s Office Customer Service Transformation Initiative, the Office of Medical Assistance Programs will be implementing changes to the old URLs to reach PROMISe hosted applications and websites. The old URLs, using a domain naming convention of dpw.state.pa.us, will be changing to dhs.pa.gov in phased implementations beginning August 7, 2024, and wrapping up in October 2024. Please review the PDF listed below, containing the impacted production environment URLs.

See document for specific PROMISE activity URL updates.

Who is Impacted?

  • CWOPA users and registered business partners with active assigned PROMISe role permissions for each URL
  • External persons accessing the Physician Provider Directory Search
  • Providers accessing the Electronic Enrollment Application or logging into the MA and LiHeap Provider Internet Portals

When is this happening?

  • The first URL, Project Workbook access, is scheduled to change on August 7, 2024
  • The remaining URLs will be implemented in phases
  • All phases to be completed by October 1, 2024

How will these changes be communicated?

  • CWOPA users and business partners with active assigned PROMISe role permission to access URLs today will receive targeted email communication shortly before each URL change is implemented
  • Broadcast messages will run on the MA Provider and LiHeap Internet Portals
  • Providers will receive the same messaging via the ListServ
  • For a limited time after implementation, if a user tries to access an old dpw.state.pa.us URL, a redirect message will pop-up for 5 seconds instructing users to save/bookmark the new URL, then continue to the new dhs.pa.gov URL
  • The DHS Communications Office will be making pre-identified updates from old URLS to the new URLs throughout the various DHS website pages

What can I do to aid this transition?

  • The Old PROMISe URLS have been in place for a long time. We are asking for your assistance, post implementation, in identifying any remaining reference to the old URL. These references could be found on DHS SharePoint, HealthChoices Extranet, and DHS web pages or downloadable documents
  • If you discover remaining usage of the old URLs post implementation, please send a message to this email for correction. Be sure to document the exact site location of the reference and include a screen shot to aid in correction efforts.

If you have further questions, please contact the above OMPA Ra account or your respective RCPA Policy Director.

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Early bird rates for the 2024 RCPA Conference Embracing Challenges, Empowering Success are ending August 23, meaning you won’t want to wait any longer to claim your seat, book that hotel room, and get ready to make new connections! Register today to gain access to over 60 thought-provoking workshops and speakers who are at the forefront of change in health and human services, including:

  • Pennsylvania’s Department of Human Services Secretary Val Arkoosh, who will cover the State of the State, identifying both current priorities and upcoming initiatives; and
  • Vice President for State Partnerships and Innovation Donna Martin of ANCOR and Senior Vice President of Public Policy and Advocacy Reyna Taylor of the National Council for Mental Wellbeing, who will give national updates on practices being implemented nationwide as well as legislative updates from Washington, DC.

View our registration brochure for complete details on the conference schedule, current sponsors and exhibitors, and a word from RCPA President and CEO Richard Edley.

Time is also running out if your organization is interested in sponsoring or exhibiting at our conference — the deadline for items is August 23, 2024! Now is your chance to complete our Sponsors, Exhibitors, and Advertisers Brochure or contact Carol Ferenz, Conference Coordinator, for opportunities to showcase your organization.

We look forward to sharing more details in the near future and would like to extend a thank you to those organizations who have already pledged support for the conference! View our current sponsors and exhibitors on the RCPA Conference website!

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The Centers for Medicare and Medicaid Services (CMS) has recognized traumatic brain injury (TBI) as a chronic health condition. TBI has been added to CMS’ list of chronic conditions for chronic special needs plans (C-SNPs) through its Medicare Advantage program, effective for the January 2025 plan year.

The addition of TBI to the list of chronic conditions was included in a final rule published by CMS in the June 2024 Federal Register, which will become effective on January 1, 2025. Obtaining official recognition of TBI as a chronic condition from CMS is a significant step forward and provides validation that brain injury should be more broadly recognized as a chronic condition.

In March 2024, the Brain Injury Association of America (BIAA) published a position paper requesting CMS, along with the Centers for Disease Control and Prevention (CDC), to designate brain injury as a chronic condition. Formal recognition, the paper states, has the potential to provide several advantages for people with brain injury, including the allocation of additional public health resources to focus on the lifelong effects of brain injury as well as health insurance plans, primarily Medicare and Medicaid, providing additional benefits and other supports as they do for other chronic health conditions. The greatest benefit, however, would be an increase in public awareness of the long-term effects of brain injury that affect the estimated 5 million Americans with a brain injury-related disability.

BIAA will be hosting a live Question and Answer (Q&A) session in the near future to discuss these changes and future tools and resources to assist survivors and their loved ones advocate for further expanding coverage.

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