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Tags Posts tagged with "centers for medicare and medicaid services"

centers for medicare and medicaid services

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During the November Centers for Medicare and Medicaid Services (CMS) National Provider call with inpatient rehabilitation facilities (IRFs), CMS responded to a question related to the counting of minutes of therapy provided by a therapy student that these minutes would not count, regardless of the level of supervision.

This triggered much confusion and led to the therapy professional associations requesting a meeting with CMS to discuss and address this and their concerns surrounding this response. After this collaborative effort between these associations and CMS, CMS issued a clarification of its position on therapy students in IRFs.

CMS has noted that student therapists may participate in therapy provided in an IRF if the student is appropriately supervised, and that the time spent with the student may count towards satisfying intensity of therapy requirements for IRFs. Cited directly from the clarification:

“Regarding the IRF intensive rehabilitation therapy program requirement in 42 CFR 412.622(a)(3)(ii), CMS’s current policy does not prohibit the therapy services furnished by a therapy student under the appropriate supervision of a qualified therapist or therapy assistant from counting toward the intensive rehabilitation therapy program. However, IRFs provide a very intensive hospital level of rehabilitation therapy to some of the most vulnerable patients. To ensure the health and safety of this vulnerable population, CMS expects that all student therapy services will be provided by students under the supervision of a licensed therapist allowed by the hospital to provide such services.”

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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The Centers for Medicare and Medicaid Services (CMS) released Change Request (CR) 11055, “Annual Update to the Per-Beneficiary Therapy Amounts.” This CR provides information on the annual per-beneficiary incurred expense amounts, now known as the KX modifier thresholds, and related policy updates for calendar year (CY) 2019. These amounts were previously associated with the financial limitation amounts (therapy caps) before the application of the therapy caps was repealed when the Bipartisan Budget Act (BBA) of 2018 was signed into law.

For CY 2019, the KX modifier threshold amount for physical therapy (PT) and speech-language pathology (SLP) services combined is $2,040. For occupational therapy (OT) services, the CY 2019 threshold amount is $2,040.

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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On November 15, 2018, the Centers for Medicare and Medicaid Services (CMS) held a National Provider Call for inpatient rehabilitation facilities (IRFs) that focused on the changes included in the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule.

CMS has posted the presentation from this call and recently posted both the audio recording and transcript. RCPA encourages all members in the Rehabilitation Services Division to listen to this recording or read the transcript from this call. Questions can be directed to Melissa Dehoff.

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On Tuesday, November 27, 2018, the RAND Corporation (a contractor for the Centers for Medicare and Medicaid Services), will hold a stakeholder meeting to discuss their results from the Improving Medicare Post-Acute Care Transformation (IMPACT) Act national beta test of candidate standardized patient assessment data elements (SPADEs). They will also discuss areas of support and key concerns raised by stakeholders during prior engagement activities and answer questions from attendees.

The meeting will be held at the RAND offices, 1200 South Hayes St., Arlington, VA 22202-5050, from 12:00 pm to 4:00 pm.

Attendees can register to attend in person or by phone using the links below. The limited number of in-person spaces will be available on a first-come, first-served basis.

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.

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ODP Announcement Number 100-18 provides an update regarding feedback to providers after the completion of self-assessments this summer. Due to the amount of analysis needed and the quantity of self-assessments received, ODP began to email providers this week. The email contains a report for each self-assessment completed per service location along with guidance on how to correct areas on the self-assessment that could potentially be non-compliant according to Centers for Medicare and Medicaid Services (CMS) HCBS Final Rule.

ODP began emailing residential providers who completed a self-assessment starting Monday, November 5, 2018. It will take at least two weeks for ODP to email all residential providers. Non-residential providers will begin to receive emails starting Monday, November 19, 2018. If a provider does not receive a report for all of their service locations for which they completed a self-assessment by November 30, 2018, please contact ODP via email.

Please note that if a new service location has opened since June 12, 2018 (the date the HCBS Provider Settings Self-Assessment process officially closed), a self-assessment is not required to be completed for that service location. The only exception is for new Life Sharing homes that will provide services to individuals in the Community Living Waiver, for which a self-assessment must be completed. ODP will assess compliance with the CMS HCBS Final Rule for all other new service locations through multiple processes such as licensing, Quality Assessment and Improvement (QA&I), and approved program capacity and noncontiguous clearance.

For questions related to this communication, please contact ODP via email.

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The Centers for Medicare and Medicaid Services (CMS) has released the updated Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) Measure Calculations and Reporting User’s Manual (Version 3.0). This version of the manual is effective on October 1, 2018. The manual provides detailed information for IRF Patient Assessment Instrument (PAI) based quality measures, including inclusion and exclusion criteria, quality measure definitions, and measure calculation specifications. All of the materials are available on the Downloads section located at the bottom of the IRF Quality Reporting Measures Information web page.

Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with any questions.

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The Centers for Medicare and Medicaid Services (CMS) published the fiscal year (FY) 2019 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule in the August 6, 2018 Federal Register.

Removal of the FIM Instrument and Revisions to the IRF PPS Case-Mix Groups
RCPA was discouraged to see that CMS finalized its proposals to enact new case-mix groups (CMGs) based on function data from the Quality Indicators section of the inpatient rehabilitation facility patient assessment instrument (IRF PAI) and remove the Functional Independence Measures (FIM) instrument from the IRF PAI effective October 1, 2019 (FY 2020). On a positive note, CMS will now have two years of data (FY 2017–2018) in its analysis to develop the FY 2020 CMGs rather than using FY 2017 data alone as originally proposed. CMS has indicated that any changes to the revised CMG definitions will be addressed in future rulemaking prior to implementation in FY 2020. In addition, CMS states it plans to provide training and educational resources on the data items in the Quality Indicators section of the IRF PAI before the new policies take effect on October 1, 2019. The final rule does not include additional analytical reports or data beyond what was published in the proposed rule, but members are encouraged to review the technical report that was referred to in the proposed rule (Analyses to Inform the Potential Use of Standardized Patient Assessment Data Elements in the Inpatient Rehabilitation Facility Prospective Payment System by RTI International).

Changes to IRF PPS Coverage Requirements
CMS adopted all of its proposals relating to the IRF coverage requirements, including:

  • Proposal to allow the Post-Admission Physician Evaluation to count towards one of the required three weekly face-to-face physician visits during the first week of a patient’s stay in an IRF.
  • Remote physician attendance and allowance to lead discussion at interdisciplinary team meeting without any additional documentation requirements. CMS notes that hospitals would still be able to set their own policies about remote attendance, and that this proposal would alleviate documentation burden on physicians and allow the physicians “increased flexibility for time management.”
  • Admission order documentation requirement. CMS adopted its proposal to remove the requirement under the IRF PPS regulations that there be a physician order for inpatient care in the medical record. CMS believes this requirement is duplicative of the requirements under the Medicare Conditions of Participation (CoPs) regulations as well as the requirements under the general Medicare Part A payment regulations that are applicable to IRFs. Therefore, even though this requirement is eliminated, there will still need to be an admission order when a patient is admitted to an IRF since IRFs must adhere to all CoPs.
  • Input on additional changes to the physician supervision requirements. CMS requested input on two areas being considered for future changes. The first area is whether some of the three weekly required physician visits could be completed remotely. The second area CMS requested information on was the use of non-physician practitioners, such as physician assistants, to satisfy some of the coverage criteria that must currently be completed only by a physician. CMS did not provide a detailed response to comments submitted, but said it would consider these stakeholder comments for future rulemaking.

Proposed Changes to IRF QRP
CMS adopted its proposals to remove two measures from the IRF quality reporting program (QRP):

  • National Healthcare Safety Network (NHSN) Facility-wide Inpatient Hospital-onset Methicillin-resistant Staphylococcus aureus (MRSA) Bacteremia Outcome Measure (NQF #1716).
    • IRFs will no longer be required to submit data on this measure for the purposes of the IRF QRP beginning with October 1, 2018 admissions and discharges.
  • Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680).
    • Providers will no longer be required to submit data on this measure for the purposes of the IRF QRP beginning with patients discharged on or after October 1, 2018. The IRF-PAI data items associated with reporting this measure (O0250A, O0250B, and O0250C) will be removed from the IRF-PAI version 3.0 effective October 1, 2019.
    • Beginning with October 1, 2018 discharges and until IRF-PAI version 3.0 is effective, IRFs should enter a dash (–) for items O0250A, O0250B, and O0250C. CMS states that it will provide ongoing guidance to providers to clarify that use of a dash for these assessment items beginning October 1, 2018 is appropriate and will not cause a non-compliance determination.

CMS finalized its proposals to begin publicly displaying data on the following four assessment-based measures in CY 2020, or as soon thereafter as technically feasible:

  • Change in Self-Care (NQF #2633);
  • Change in Mobility Score (NQF #2634);
  • Discharge Self-Care Score (NQF #2635); and
  • Discharge Mobility Score (NQF #2636).

Changes to the IRF PPS Payment Rates for FY 2019
CMS finalized most of its payment proposals for FY 2019. However, it made small adjustments to the originally proposed outlier threshold and labor-related share due to updated data that had become available since the proposed rule.

RCPA was asked to submit a letter of support from the House Ways and Means Committee; view a copy of that letter here.

These regulations become effective on October 1, 2018. For additional information, CMS has posted a fact sheet. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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The Centers for Medicare and Medicaid Services (CMS) has released the calendar year (CY) 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. The proposed rule would revise the Medicare hospital OPPS and the Medicare ambulatory surgical center (ASC) payment system for calendar year 2019. Included are proposed changes to the amounts as well as factors used to determine the payment rates and update and refine the requirements for the quality reporting programs (QRP). Some of the proposed highlights include a proposal to pay for visits at excepted off-campus provider-based departments at a Physician Fee Schedule (PFS) equivalent payment rate, which would result in lower copayments for beneficiaries and a savings to the Medicare program; reduction to the number of measures required to report under their quality reporting programs; and modifying the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) patient experience of care survey measure by removing the three recently revised pain communication questions beginning with January 1, 2022 discharges, which would avoid any potential unintended consequences of possible opioid overprescribing.

The proposed rule will be published in the July 31, 2018 Federal Register. Comments will be accepted through September 24, 2018. Contact Melissa Dehoff, RCPA Director of Rehabilitation Services, with questions.

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It has been reported that the Centers for Medicare and Medicaid Services (CMS) has issued letters of non-compliance to Inpatient Rehabilitation Facilities (IRFs) specific to the IRF quality reporting program (QRP) requirements for the data collection period affecting federal fiscal year (FFY) 2019 reimbursement. IRFs that did not meet the IRF QRP reporting requirements will receive a two percent payment reduction on their IRF prospective payment system (PPS) annual increase factor in FY 2019.

IRFs found to be non-compliant should have received notification from their Medicare Administrative Contractor (MAC) and are also expected to receive a letter in their provider Certification and Survey Provider Enhanced Reporting (CASPER) folder with specific details regarding the missing quality reporting data. Additional information on the data collections requirements and submission timeframes for FY 2019 compliance determination can be found in the CMS Data Collection & Final Submissions table posted on the CMS website, as well as the CMS IRF QRP website.

IRFs that feel they have received a non-compliance notification letter in error may request CMS reconsideration of the decision. Providers have 30 days to file a reconsideration request. Detailed filing instructions can be found on the IRF Quality Reporting Reconsideration and Exception & Extension web page.

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The Centers for Medicare and Medicaid Services (CMS) has scheduled a call on Thursday, June 21, 2018 at 2:00 pm that will focus on and provide additional information about the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. During the call, CMS will answer frequently asked questions (FAQs) on quality measures, standardized data elements, the CMS data element library, and future directions of the IMPACT Act. Members that wish to participate in the call must register. Send any questions or request assistance with registration via email.

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