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CMS

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The Inpatient Rehabilitation Facility (IRF) Provider Preview Reports have been updated and are now available. These reports contain provider performance scores for quality measures, which will be published on Care Compare and the Provider Data Catalog during the Care Compare refresh in December 2022. For additional information, please visit the CMS IRF Quality Reporting Program (QRP) Public Reporting website. The deadline to review the information is October 17, 2022.

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The Centers for Medicare and Medicaid Services (CMS) has issued a quarterly (consolidated from June 2020 to September 2022) inpatient rehabilitation facility patient assessment instrument (IRF-PAI) Question and Answer (Q&A) document in light of the release of the IRF-PAI 4.0. This document focuses on questions submitted to the IRF Quality Reporting Program (QRP) Help Desk related to the IRF-PAI version 4.0 and consolidates guidance from prior releases.

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The Centers for Medicare and Medicaid Services (CMS) has released a Request for Information (RFI) that seeks public input on accessing healthcare and related challenges, understanding provider experiences, advancing health equity, and assessing the impact of waivers and flexibilities provided in response to the COVID-19 Public Health Emergency (PHE).

The Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs RFI furthers CMS’ commitment to engaging and learning from partners, communities, and individuals across the health system to inform how we can better support the populations we serve. In alignment with Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, the CMS Strategic Plan Pillar: Health Equity, and the CMS Framework for Health Equity (2022–2032), this RFI aims to gather feedback and perspectives related to challenges and opportunities for CMS to embed health equity into their efforts encouraging innovation, reducing burden, and creating efficiencies across the healthcare system.

CMS is seeking to better understand individual and community-level burdens, health-related social needs, and opportunities for improvement that can reduce disparities and promote efficiency and innovation across programs. CMS is requesting information related to strategies that successfully address drivers of health inequities, including opportunities to address social determinants of health and challenges underserved communities face in accessing comprehensive, quality care. For example, challenges accessing care may include understanding coverage options, receiving culturally and linguistically appropriate care, accessing oral health services, and accessing comprehensive and timely healthcare services and medication.

Through this RFI, CMS also seeks to better understand the factors impacting provider wellness and learn more about the distribution of the healthcare workforce. CMS is particularly interested in understanding the greatest challenges for healthcare workers in meeting the needs of individuals, and the impact of CMS policies, documentation, and reporting requirements, operations, and communications on provider experiences.

Comments received in response to the Make Your Voice Heard RFI will be used to identify opportunities for improvement and to increase efficiencies across CMS programs. In addition, CMS hopes to learn how specific programs have benefited providers, practices, and the people served.

CMS encourages comments from all interested stakeholders, in particular, patients and their families, providers, clinicians, consumer advocates, and healthcare professional associations. CMS also encourages comments from individuals serving and located in underserved communities and from all CMS stakeholders serving populations facing disparities in health and healthcare. The RFI is open for a 60-day public comment period.

Comments must be received by November 4, 2022, to be considered.

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The Centers for Medicare and Medicaid Services (CMS) recently released a Request for Information (RFI) requesting public comments on the Medicare Advantage program. CMS is asking for input on ways to achieve the agency’s vision so that all parts of Medicare are working towards a future where people with Medicare receive more equitable, high quality, and person-centered care that is affordable and sustainable, essentially asking for ways to strengthen this program.

CMS’s intent is to better align the Medical Assistance (MA) program with the agency’s vision for Medicare and the CMS Strategic Pillars. CMS is strongly emphasizing the importance of stakeholder comments for this process. This openness to feedback presents MA plans, providers, and other stakeholders an opportunity to inform the agency’s early thinking as it considers potential regulatory actions impacting supplemental benefits, value-based contracting arrangements, risk adjustment, prior authorization, and marketing among other issues.

CMS will accept comments on the RFI until August 31, 2022.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was published in today’s Federal Register. Some of the key provisions contained in the final rule are provided below:

Final FY 2023 Payment Updates
CMS estimates overall payments to IRFs will increase by 3.2 percent compared to FY 2022 levels (higher than the 2 percent estimated in the proposed rule). This update is the result of a 4.2 percent update to the IRF market basket reduced by a 0.3 percent productivity adjustment, which is required by law. As a result of this market basket increase and a few small budget neutrality adjustments, the standard payment conversion factor will increase from $17,240 to $17,878. ‎CMS is also adjusting the outlier threshold, which it says will reduce overall payments by 0.6 percent. CMS says the 3.2 percent overall increase will result in $275 million in increased payments to IRFs compared to 2022.

Proposed Expansion of IRF Transfer Policy to Include Home Health Services
CMS issued a Request for Information (RFI) in the proposed rule regarding the potential expansion of the current IRF transfer payment policy to include home health services. For background, IRFs receive a reduced case mix group (CMG) payment rate under the IRF transfer policy when the patient’s discharge occurs earlier than the average length of stay (for that respective CMG and tier) and the patient is discharged to a certain setting (an IRF, acute-care hospital, LTCH, nursing home that takes Medicare and Medicaid payment). The policy currently does not apply to home health.

The RFI in this year’s rule followed a December 2021 Office of Inspector General (OIG) report finding that Medicare could have saved over $993 million had the IRF transfer policy been expanded to include home health services (based on 2017 and 2018 data). The OIG therefore recommends that CMS explore ways to capture early discharges to home health care in the current policy, which CMS referenced in the proposed rule. Following a review of concern cited in stakeholder comments, CMS is not moving forward with any changes to the transfer policy at this time.

IRF Quality Reporting Program Changes & Requests for Information All-Payer IRF-PAI Reporting Proposal
CMS proposed to require collection of the IRF-PAI for all IRF patients, including those without Medicare, beginning with the FY 2025 IRF QRP (with data collection to begin on October 1, 2023). Currently the IRF-PAI is only required to be collected for Medicare Part A (fee-for-service) and Part C (Medicare Advantage) beneficiaries. In response to comments, CMS opted to finalize the proposal but with a revised implementation date. IRFs will now be required to collect IRF-PAIs on all patients, regardless of payer, for the FY 2026 IRF QRP (data collection to begin on October 1, 2024).

RFI on Future QRP Measure Expansions
CMS had issued a Request for Information (RFI) related to measures/concepts for use in the QRP in future years in the proposed rule. The agency specifically requested information on a cross-setting function measure that would include self-care and mobility items, and development of a patient-level COVID-19 vaccination measure. CMS referenced several of AMRPA’s comments, including concerns that IRF stays are typically not long enough to adequately capture COVID-19 vaccination for patients. CMS did not provide a response to comments but affirmed the agency would use the stakeholder feedback to inform future rulemaking.

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