CMS Issues FY 2021 IRF PPS Final Rule
The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2021 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule. The provisions contained in this final rule will go into effect on October 1, 2020 and will be published in the August 10, 2020 Federal Register.
Some of the key provisions contained in the final rule include:
Increased Flexibility for Physicians
CMS significantly scaled back its proposal to allow non-physician practitioners (NPPs) to perform certain IRF services that are currently required to be performed by a rehabilitation physician, such as completing the pre-admission screening, developing the individual overall plan of care (IOPC), performing three face-to-face visits per week, and leading interdisciplinary team meetings. CMS noted that the role and judgment of the rehabilitation physicians are key to the successful outcomes complex IRF patients.
IRF Coverage Requirements
CMS finalized certain changes to the regulations that codifies existing documentation instructions and guidance that improves clarity and reduces administrative burden on both the IRF providers and the Medicare Administrative Contractors (MACs).
Post-Admission Physician Evaluation
IRF’s are required to conduct a post-admission physician evaluation (PAPE) within the first 24 hours of the patient’s admission to the IRF to confirm that no changes have occurred since the preadmission screening and that the patient is still appropriate for IRF admission. The PAPE requirement was temporarily waived as an IRF coverage requirement under the April 6, 2020 interim final rule in response to the COVID-19 public health emergency (PHE). In the proposed rule, CMS stated that it intended to utilize the temporary removal of the PAPE to gauge the impact of permanently removing this documentation requirement. This proposal to make permanent this temporary removal of the PAPE was finalized in this rule.
Intensity of Therapy
CMS clarifies that a “week” will be defined as a period of 7 consecutive calendar days beginning with the date of admission to the IRF; thereby, clarifying for purposes of compliance with the so-called “3 hour rule.”
Quality Reporting Program (QPP)
CMS finalized the method for applying the 2 percentage point reduction (i.e., penalty) to the FY 2021 IRF increase factor for IRFs that fail to meet Quality Reporting Program (QRP) requirements. This is the only provision impacting the QRP in the FY 2021 rule.
Updates to IRF Payment Rates
For FY 2021, CMS is updating the IRF PPS payment rates by 2.4 percent (reflecting a 2.4 percent IRF market basket reduced by a 0.0 percentage point multifactor productivity adjustment). An additional 0.4 percent increase to aggregate payments due to updating the outlier threshold to maintain estimated outlier payments at 3.0 percent of total payments results in an overall update of 2.8 percent (or $260 million) for FY 2021, relative to payments in FY 2020. The recent Office of Management and Budget (OMB) statistical area delineations and applying a 5 percent cap on wage index decreases from FY 2020 to FY 2021 are also being adopted. The wage index files are available on the CMS website.
