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The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2024 inpatient rehabilitation facility (IRF) prospective payment system (PPS) final rule in the August 2, 2023, Federal Register. Some of the key provisions contained in the final rule include:

Payment and Coverage Provisions

  • FY 2024 Market Basket Update and Productivity Adjustment: For the FY 2024 IRF PPS payment adjustments, CMS estimates that ‎IRFs will see a 4.0 percent increase in total payments (totaling an increase of $355 million) ‎relative to FY 2023. This update is a result of a 3.6 percent market basket update, minus a ‎‎0.2 percent productivity adjustment.
  • 2021-Based IRF Market Basket: The final rule rebases and revises the IRF market ‎basket to reflect a 2021 base year (which reflects more recent data). ‎Moving forward, CMS says that it will “continue to monitor the Medicare cost report ‎data as they become available” and consider updates to the IRF market basket in future ‎rulemaking.‎
  • Case Mix Groups: Consistent with the proposed rule, CMS estimates that the vast ‎majority of cases will be in case mix groups (CMGs) and tiers that will see a ‎change of less than 5 percent in FY 2024. ‎
  • Outlier Threshold: CMS is finalizing the outlier threshold amount of $10,423, which is estimated to be ‎approximately 3 percent of the total estimated aggregate IRF payments in 2024. CMS also ‎notes that finalized changes in the Average Length of Stay (ALOS) values for FY 2024, ‎compared with FY 2023 ALOS values, are small and do not show any particular trends ‎in IRF length of stay patterns.
  • Wage Adjustments and Labor-Related Share: CMS finalized proposals to update the ‎wage index adjustments using the same methodology and factors as previous updates. ‎Based on forecasts, the total labor-related share for FY ‎‎2024 is 74.1 percent (the sum of 70.3 percent for operating costs and 3.8 percent for the labor-related share ‎of Capital-Related costs).
  • Impact Estimate: Overall, the estimated payments per discharge for IRFs in FY 2024 ‎are projected to increase by 4.0 percent, compared with the estimated payments in FY 2023. ‎IRF payments per discharge are estimated to increase by 4.0 percent in urban areas and 3.6 percent ‎in rural areas, compared with estimated FY 2023 payments. Payments per discharge to ‎rehabilitation units are estimated to increase 4.5 percent in urban areas and 3.9 percent in rural ‎areas. Payments per discharge to freestanding rehabilitation hospitals are estimated to ‎increase 3.7 percent in urban areas and 2.8 percent in rural areas.‎
  • Modifications for Excluded IRF Units: Consistent with the proposed rule, CMS is ‎finalizing new flexibilities for rehabilitation units that are seeking to be excluded from ‎the acute inpatient PPS and paid under the IRF PPS for the first time. Hospitals will now ‎be allowed to open a new IRF unit (and get paid as such) at any time within the cost ‎reporting year, instead of being limited to only the beginning of a cost reporting period. ‎The hospital must notify the CMS Regional Office and Medicare Administrative ‎Contractor (MAC) in writing at least 30 days before the change. If a unit becomes ‎excluded during a cost reporting year, that change must remain in effect at least through ‎the rest of that cost reporting period. ‎

Quality Reporting Program (QRP) Provisions: ‎CMS finalized all of the proposed changes related to quality measures for the IRF QRP put forth in the proposed ‎rule. The following changes have been finalized for the IRF QRP:

  • Implementation of the New COVID-19 Vaccine for Patients: Data collection for the ‎‎“Percent of Patients/Residents Who Are Up-to-Date” will be placed on an updated IRF-‎Patient Assessment Instrument (PAI) and begin with discharges on or after October 1, 2024, for use in the FY 2026 IRF ‎QRP.‎
  • Update of the COVID-19 Vaccination Measure for Healthcare Personnel: CMS ‎finalized its proposed modification of the COVID-19 Vaccination Coverage among‎ ‎Healthcare Personnel (HCP COVID-19 Vaccine) measure‎ to include the CDC “up-to-‎date” consideration for reporting purposes. Data collection for this modification is to ‎begin October 1, 2023, for use in the FY 2025 IRF QRP.‎
  • Implementation of the New Discharge Function Score Measure: No new data ‎collection is required, but the calculations and reporting of this measure will begin with ‎discharges on or after October 1, 2023, for use in the FY 2025 IRF QRP.‎
  • Measure Removal: Three measures have been removed from the IRF QRP and will no ‎longer require the collection of certain data elements for discharges on or after October ‎‎1, 2023:‎
    • Application of Percent of Long-Term Care Hospital Patients with an Admission ‎and Discharge Functional Assessment and a Care Plan That Addresses Function;
    • IRF Functional Outcome Measure: Change in Self-Care Score for Medical ‎Rehabilitation Patients (CBE #2633)‎; and
    • IRF Functional Outcome Measure: Change in Mobility Score for Medical ‎Rehabilitation Patients (CBE #2634)‎.
  • New Public Reporting: CMS announced the start of public reporting for the following ‎measures:‎
    • Transfer of Health (TOH) Information to the Provider — Post-Acute Care (PAC) ‎Measure (TOH-Provider) beginning with September 2025 Care Compare refresh ‎‎(even though proposed rule and other language in final rule stated September ‎‎2024 Care Compare refresh)‎. CMS staff has been alerted to this discrepancy.
    • TOH Information to the Patient — PAC Measure (TOH-Patient) beginning with ‎September 2025 Care Compare refresh (even though proposed rule and other ‎language in final rule stated September 2024 Care Compare refresh)‎.
    • Discharge Function Score Measure — Beginning with the September 2024 Care ‎Compare refresh or as soon as technically feasible.‎
    • COVID-19 Vaccine: Percent of Patients/Residents Who Are Up-to-Date Measure — Beginning with the September 2025 Care Compare refresh or as soon as ‎technically feasible.‎

CMS also released a fact sheet on the final rule. The data files associated with the final rule, including the wage index tables, the rate setting data for each IRF, and the ‎final tables for case-mix groups, relative weights, and average lengths of stay are also available. Unless otherwise ‎noted above, the provisions in the final rule will take effect on October 1, 2023. ‎

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Best Practices When Working With Medical Interpreters in Therapeutic Settings
Monday, September 11, 2023
1:00 pm – 2:00 pm EDT; 12:00 pm – 1:00 pm CDT;
11:00 am – 12:00 pm MDT; 10:00 am – 11:00 am PDT
REGISTER

Sally De Arruda, MSHA

Speaker Bio:
Azalia (Sally) De Arruda is a medical interpreter and the Language Service Manager at Mt. Washington Pediatric Hospital in Baltimore, Maryland, where she has worked for the past 16 years. Sally began her career in the Admissions Department and was instrumental in the creation of the hospital’s Language Service Program that she now leads.

Sally holds a Master’s Degree in Health Administration and has specialized training as a medical interpreter, including coursework in The Community Interpreter 40-hour training course, Medical Terminology, Qualified Bilingual Staff Program, and ACTFL Oral Proficiency Interview.

Sally is passionate that all patients should receive the best possible care, including those with limited English proficiency. Through her work on and with the rehabilitation team, Sally has developed a robust program to ensure that the best possible rehabilitation care be provided even when language barriers are present.

Objectives: At the end of this session, the learner will:

  • Identify the key differences between an interpreter and a translator;
  • Recognize behaviors, practices, or pitfalls to avoid when working with a medical interpreter;
  • Implement three practical ways for a clinician to interact with a medical interpreter during a medical appointment; and
  • Discuss the value of a medical interpreter as a member of the rehab team.

Audience: This webinar is intended for all members of the rehabilitation team, including medical staff, nurses, physical therapists, occupational therapists, speech language pathologists, licensed psychologists, mental health professionals, and other interested professionals.

Level: Intermediate

Certificate of Attendance: Certificates of attendance are available for all attendees. No CEs are provided for this course.

Registration: Registration is complimentary for members of IPRC/RCPA. Registration fee for non-members is $179. Not a member yet? Consider joining today. Multiple registrations per organization are permitted.

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A Frontline Story on Adopting Augmented Intelligence for Behavioral Health: Gaudenzia + Eleos Scribe
August 8, 2023, 1:00 pm ET
Register Here

With provider burnout and turnover rates on the rise, top behavioral health organizations are turning to augmented intelligence to help reduce administrative burdens for frontline staff, improve care, and enhance their ability to scale training and supervision.

Join us for a special webinar event on August 8 from 1 to 2 pm ET where we’ll welcome Andrew Schmitt, LCSW, Director of Outpatient Services for Gaudenzia, Inc., to share his first-hand insights on what it’s like to navigate organizational and technological transformation in behavioral health—and how Gaudenzia has used Eleos Scribe to reduce documentation time by 70% and increase the use of evidence-based techniques 35%.

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For those in health and human services, keeping up-to-date with the latest in payment, treatment, and worker recruitment methods is essential. At the 2023 RCPA Annual Conference A Decade of Unity, you’ll have access to workshops that both highlight and educate on the latest developments in the field, including the use of AI, selective contracting, and telehealth. Our full brochure is available, and you can expect to see workshops such as the following:

  • Guiding the Use of Evidence-Based Practice to Drive Improved Quality Outcomes Across Levels of Care
    • Examine the use of evidence-based practices and the outcomes of value-based payment programs with the PA Opioid Use Disorder Centers of Excellence.
  • Recruitment and Retention of Front Line Workers
    • Focus on the HR challenges of recruiting and retaining workers by reviewing why workers are leaving and analyzing what HR can do to meet goals.
  • Preparing Your Organization’s Infrastructure for Selective Contracting for IDD Providers
    • Define what a preferred IDD provider is when it comes to selective contracting and discuss how to prepare for transitioning your organization’s infrastructure.
  • Not If But When You Use AI and Machine Learning – But is the AI Trustworthy? Some Things to Look For
    • Discuss AI use in the health and human services field in order to make informed decisions for your organization.
  • Connecting Through Movement: Bringing Accessible and Enjoyable Movement Experiences Into the Home and Community
    • Explore ways of staying physically active in community settings with home-based, telehealth methods.
  • A Brief Multi-Disciplinary Intervention for Supporting Adults With IDD and Co-Occurring Mental Health Conditions
    • Analyze the use of the ANSA-DD for holistic intervention and treatment for those with IDD and co-occurring mental health conditions.
  • Community Partnerships That Work: Community Mental Health Centers – School Districts
    • Identify the strengths in collaboration when school districts, community mental health agencies, and their communities work together to assist families struggling with violence and trauma.
  • Leadership and Navigating Change
    • Tackle resistance in a team that is going through significant adjustments and learn how to be a leader by focusing on the ‘people side’ of change.
Register today!

In addition to an impressive roster of speakers, our 2023 Conference will have an exciting array of sponsors and exhibitors. We thank those who have signed on thus far! If you are interested in sponsoring or exhibiting, visit here for more details or contact Carol Ferenz, Conference Coordinator, with any questions you may have. Keep up-to-date and register today for #rcpaconf!

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Image by Dirk Wouters from Pixabay

The Mental Health Planning Council, under the direction of The Office of Mental Health and Substance Abuse Services (OMHSAS), is conducting a survey on delivering Intensive Behavioral Health Services (IBHS) and is requesting assistance in provider responses to the survey. Agencies may access the provider survey directly and view the flyer for more details. Feedback will be de-identified and compiled by the Family Satisfaction Team of Montgomery County to be shared with relevant stakeholders and survey participants.

Data collection for the survey will run from August 1, 2023 – August 31, 2023.

RCPA, on behalf of our members and those they serve, continues our efforts advocating for children, families, and practitioners delivering IBHS services. We respectfully ask our members to share this survey with families they are currently serving. The information will be utilized to examine challenges and opportunities in creating more viable pathways to IBHS services. Feel free to also share this information with other providers in your network of stakeholders.

If you have questions, please contact Clare Higgins or RCPA Policy Director Jim Sharp.

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Capitol hill building in the morning with colorful cloud , Washington DC.

Message from the National Council for Mental Wellbeing:

This month the National Council for Mental Wellbeing and hundreds of other organizations across the country celebrated the first anniversary of the 988 Suicide and Crisis Lifeline, a new dialing code operated through the existing National Suicide Prevention Lifeline. With the new, easy to remember number, the Lifeline successfully served millions more people than in years prior.

Yet we still have a long way to go to ensure that our crisis care system provides people in every community with someone to respond and somewhere to go.

Recently, Representative Tony Cardenas (D-CA-29) introduced the 988 Implementation Act, bipartisan legislation that seeks to provide federal funding and support for states to enact 988 crisis services and broaden awareness of resources for those in crisis.

What is the 988 Implementation Act? 

  1. Expands behavioral health workforce training programs and provides grant opportunities for local behavioral health centers;
  2. Expands Medicaid coverage for behavioral health services, including short term crisis intervention services;
  3. Increases support for mobile crisis response, ensuring that even those in rural areas have access to timely care;
  4. Creates new capital grants to be used for crisis response program facility renovation, construction, and expansion;
  5. Narrows the IMD exclusion so that services furnished in psychiatric acute care crisis beds administered by CCBHCs and other crisis care settings are eligible for Medicaid coverage; and
  6. Increases awareness of 988 through a national media campaign.

Contact your Congressional Representatives and urge them to support the 988 Implementation Act. By strengthening, and raising awareness for current resources, and building capacity at the state level for on the ground crisis services, this legislation will make a difference, and save lives.

Time is of the essence. Act today, and together we can strengthen the crisis care continuum.

Sincerely,
Rachel Abraham
Federal Policy and Advocacy Coordinator
The National Council for Mental Wellbeing

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