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Tags Posts tagged with "FY 2024"

FY 2024

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The PA Provider Advocacy Coalition, an organization that constitutes a variety of PA providers and advocates across all fields, recently sent a letter to the Shapiro Administration regarding the FY 2024/25 budget. RCPA signed onto the letter, which calls for rate adjustments and investments in Medicaid services in order to address the current workforce crisis. The Coalition states in the letter:

We recognize that addressing these workforce challenges will require a sustained, coordinated, multi-faceted public and private sector response. Earlier this year, our coalition met with representatives of your administration to recommend the creation of a Health Care Workforce Council to help lead this multiyear effort. However, there is one aspect of this overall problem that is relatively straightforward—chronic underpayment by the Medical Assistance program.

RCPA will continue to keep our members informed of updates. If you have any questions, please contact your RCPA Policy Director.

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RCPA recently joined over a dozen PA associations in delivering a joint letter to the Shapiro Administration requesting investments be made in behavioral health services for the Fiscal Year (FY) 2024/25 budget. As noted in the letter, which was compiled by the PA Provider Advocacy Coalition:

The mental health system all too often is unable to deliver the right care, at the right time and in the right setting. We recognize that there is no simple fix and that a sustained, multiyear effort by all stakeholders—the commonwealth, counties, providers, insurers, and advocates—is necessary to rebuild and create a mental health system for the 21st century.

RCPA will continue to keep our members informed of updates. If you have any questions, please contact your RCPA Policy Director.

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The Centers for Medicare and Medicaid Services (CMS) will conduct the hospital/quality initiative open door forum (ODF) tomorrow, September 6, 2023, at 2:00 pm. Some of the agenda topics for the call include:

  • FY 2024 Inpatient Prospective Payment System (IPPS)/Long-Term Care Hospital (LTCH) Final Rule:
    • IPPS Payment Updates
    • LTCH Payment Updates
    • Wage Index Proposals
    • Rural Emergency Hospital (REH) Graduate Medical Education (GME) Proposal
    • New Technology Add-on Payment Proposals
    • Social Determinants of Health
    • Physician-Owned Hospital Proposal
    • Quality Updates
    • Hospital Value-Based Payment (VBP) Updates
  • FY 2024 IPF PPS Final Rule
  • Hospital Consumer Assessment of Healthcare Providers & Systems (HCAHPS) Podcast Now Available — Updates to HCAHPS Survey Mode Adjustments
  • Hospital Outpatient Department (OPD) Prior Authorization — Facet Joint Interventions

NEW and UPDATED Open Door Forum Participation Instructions:
This call will be a Zoom webinar. To participate by webinar, register here. After registering, you will receive a confirmation email containing information about joining the webinar.

Webinar ID: 160 121 2402
Passcode: 860132

Note that, although the ODFs are now a Zoom webinar, we will only use the audio function. There is no need for cameras to be on.

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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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The Centers for Medicare and Medicaid Services (CMS) will conduct the next hospital/quality initiative open door forum on April 18, 2023, at 2:00 pm. Agenda topics include:

  • Announcements & Updates;
  • Upcoming Wage Index April PUF;
  • FY 2024 IPPS/LTCH PPS Proposed Rule; and
  • FY 2024 IPF PPS Proposed Rule.

To participate by phone, dial 888-455-1397.
Reference Conference Passcode: 4325849
Instant Replay: 866-415-8391, Conference ID: No Passcode Needed

Instant Replay is an audio recording of this call that can be accessed by dialing 866-415-8391 beginning one hour after the call has ended. The recording expires after April 21, 2023, 11:59 pm ET.

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Late yesterday, the Centers for Medicare and Medicaid Services (CMS) issued the fiscal year (FY) 2024 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

The proposed rule includes a 3.7 percent payment increase, compared to the 3.9 percent payment update that CMS finalized for FY 2023. This payment update reflects the effects of the proposed IRF market basket update for FY 2024 of 3.0 percent, which is based on the proposed IRF market basket increase factor (3.2 percent), productivity adjustment (0.2 percent), and outlier payment increase (0.7 percent).
** Please note that these figures are subject to change in the final rule if updated forecasts become available, which typically occurs.

CMS is making a number of changes to the Quality Reporting Program (QRP), including the future addition of a discharge function score measure and patient-level COVID vaccination measure as well as a modification of the current healthcare personnel COVID-19 vaccination measure to reflect the latest vaccination recommendations.

In addition, CMS is proposing to allow hospitals to open a new IRF unit and begin being paid under the IRF PPS at any time during the cost reporting period (rather than the current restrictive enrollment rules). The proposed rule does not address any of the COVID-19 PHE waivers, including the three-hour rule and virtual team conferences, nor does it include any further discussion of the expanded transfer policy (to include certain discharges under the care of home health) that was the subject of a Request for Information (RFI) in last year’s rule.

A more detailed and extensive summary of the proposed rule will be forthcoming.

The proposed rule will be published in the Federal Register for April 7, 2023. Comments on the proposed rule will be considered until 5:00 pm on June 2, 2023. For additional information, CMS also released a fact sheet.

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