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Tags Posts tagged with "IMPACT Act"

IMPACT Act

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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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On Thursday, September 28, 2017, from 2:00 pm to 3:00 pm, the Centers for Medicare and Medicaid Services (CMS) will host a special open door forum (SODF) that will provide information and solicit feedback on the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. Topics will include the goals of the IMPACT Act, RAND contract activities for item development (including pilot test results and plans for the upcoming national field test), and identifying opportunities for providers, consumers, stakeholders, researchers, and advocates to become involved over the next year. CMS welcomes questions, comments, and ideas from providers, patients, consumers, researchers, and advocates in advance or during the forum. Questions, comments, and ideas should be submitted via email. The presentation for the SODF is posted on the IMPACT Act Downloads and Videos web page.

To participate in the SODF, dial:
1-800-837-1935
Conference ID: 66557294

A transcript and audio recording of this SODF will be posted to the Special Open Door Forum website, and for downloading under the downloads section, as well as the IMPACT Act Downloads and Videos web page.

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The Centers for Medicare and Medicaid Services (CMS) recently announced a Medicare Learning Network (MLN) call that will focus on the Standardized Patient Assessment Data Collection Project. The call has been scheduled for Wednesday, March 29, 2017, from 1:30 pm to 3:00 pm EDT

During the call, information will be shared about the efforts to develop, implement, and maintain standardized Post-Acute Care (PAC) patient assessment data, including pilot testing results and plans for an upcoming national field test. Additional agenda topics include:

  • Goal of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act);
  • Timeline of activities;
  • Alpha 1 results;
  • Alpha 2 progress;
  • Plans for beta test; and
  • How to get involved.

The IMPACT Act requires the reporting of standardized patient assessment data by PAC providers, including inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs), home health agencies (HHAs), and long-term care hospitals (LTCHs).

To register for the call, please visit the MLN Registration page.

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The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2017 inpatient rehabilitation facility (IRF) prospective payment system (PPS) final rule in today’s Federal Register.

The majority of the final rule focuses on changes in the IRF Quality Reporting Program (QRP), pursuant primarily to the requirements of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. The rule continues to address implementation of the IMPACT Act requirements regarding resource use and quality measures, adding five new measures to the IRF QRP. Four measures will begin October 1, 2016, and are collected from Medicare claims data, so no additional reporting action from providers is required. These four measures include:

  • Discharge to Community – Post-Acute Care (PAC) IRF QRP (claims-based);
  • Medicare Spending Per Beneficiary (MSPB) – PAC IRF QRP (claims-based);
  • Potentially Preventable 30 Day Post-Discharge Readmission Measure for IRFs (claims-based); and
  • Potentially Preventable Within Stay Readmission Measure for IRFs (claims-based).

The remaining measure, Drug Regimen Review Conducted with Follow-up for Identified Issues, will begin October 1, 2018, and will require additional items on the IRF Patient Assessment Instrument (IRF PAI).

Other key provisions included in the final rule:

Standard Payment Rate
The standard payment rate conversion factor will increase in FY 2017 to $15,708, compared to the proposed amount of $15,674. This amount is the result of a 2.7 percent rehabilitation-specific market basket increase, minus a productivity adjustment of 0.3 percent and a 0.75 percent ACA adjustment. The FY 2016 standard payment rate conversion factor was $15,478.

CMS used the rehabilitation market basket for the first time. It was adopted last year. The standard payment update also accounts for budget neutrality factors for the wage index and labor related share of 0.9992 and for the CMG weight revisions of 0.9992 plus changes to the outlier threshold. Table 5 in the rule (not reproduced here) displays the FY 2017 payment rates.

Update to the CMG Weights, Lengths of Stay, and Comorbidities
CMS updated the Case Mix Group (CMG) weights using FY 2014 cost report data and the FY 2015 claims data as well as the average lengths of stay (ALOS) per CMG. Approximately 99.5 percent of the cases affected by the change in weights would be changed by less than 5 percent.

Outlier Threshold
CMS updates the outlier threshold amount to $7,984 from $8,658 for FY 2016 in order to maintain the outlier payments at three percent of total IRF payments in FY 2017. The national cost-to-charge ratio ceiling for FY 2017 is 1.29; the ceiling for rural IRFs is 0.522 and 0.421 for urban IRFs.

ICD-10-CM Presumptive Compliance Coding Changes
Unfortunately, CMS did not address the problems with the ICD-10-CM codes which eliminated certain key diagnoses from being allowed for consideration in calculating a provider’s presumptive compliance in meeting the 60 percent rule. The largest set of affected codes fall into the area of brain injury under IGCs 2.21 and 2.22.

CMS did, however, comment that IRFs are permitted to use “D” as an eligible seventh character for traumatic brain injury diagnosis codes on both the claim and the IRF PAI. However, for the reasons indicated in the FY 2015 IRF PPS final rule effective with discharges occurring on or after October 1, 2015, ICD-10-CM codes with the seventh character extension of “D” are not included in the ICD-10-CM versions of the “List of Comorbidities,” “ICD-10-CM Codes That Meet Presumptive Compliance Criteria,” or “Impairment Group Codes That Meet Presumptive Compliance Criteria.”

The payment changes to the rule will apply to IRF discharges on or after October 1, 2016 and before September 30, 2017. The quality reporting requirements are effective for discharges on or after October 1, 2106.

A more complete analysis of the rule will be forthcoming and reviewed/discussed extensively at the upcoming RCPA Outpatient Rehabilitation Committee meeting on Thursday, August 18, 2016, and the Medical Rehab Committee meeting on Thursday, September 8, 2016.

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A national provider call focusing on the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 has been scheduled by the Centers for Medicare and Medicaid Services (CMS). The call has been scheduled for Wednesday, October 21, 2015, from 1:00 – 3:00 pm. Agenda topics include:

  • Legislative requirements of the IMPACT Act related to the use of standardized data, quality measures, resource use, and other measures for Skilled Nursing Facilities, Inpatient Rehabilitation Facilities, Long-Term Care Hospitals, and Home Health Agencies
  • Participation in the quality measure assessment and development process
  • Opportunities for stakeholder engagement and input

To participate in this call, providers must register. Space may be limited so early registration is recommended.

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On September 10, 2015, the Medicare Payment Advisory Commission (MedPAC) conducted a public meeting to discuss Medicare issues and policy questions and approve reports and recommendations to the Congress. Included in the agenda was a session that focused on MedPAC’s task of developing a prototype prospective payment system (PPS) that spans across the post-acute care (PAC) settings, as mandated by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. The IMPACT Act requires MedPAC to submit a report to Congress regarding this by Thursday, June 30, 2016. Included in the meeting was their presentation Mandated Report: Developing a Unified Payment System for Post-Acute Care. It is expected that MedPAC will conduct multiple public meetings in the months ahead regarding the development of PAC PPS before presenting their draft recommendations.

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The Centers for Medicare and Medicaid Services (CMS) published the final rule that updates the fiscal year (FY) 2016 Medicare payment policies and rates for the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) and the IRF Quality Reporting Program (IRF QRP) in the August 6, 2015 Federal Register. Highlights of the final rule are provided below.

Changes to the Payment Rates: CMS is updating the IRF PPS payments for FY 2016 to reflect an estimated 1.7 percent increase (reflecting a new IRF-specific market basket estimate of 2.4 percent, reduced by a 0.5 percentage point multi-factor productivity adjustment and a 0.2 percentage point reduction required by law). An additional 0.1 percent increase to aggregate payments due to updating the outlier threshold results in an overall update of 1.8 percent (or $135 million), relative to payments in FY 2015.

No Changes to the Facility-Level Adjustments: As stated in the FY 2015 IRF PPS final rule, CMS froze the facility-level adjustment factors at the FY 2014 levels for FY 2015 and all subsequent years. For FY 2016, CMS will continue to hold the facility-level adjustment factors at the FY 2014 levels as they continue to monitor the most current IRF claims data available to assess the effects of the FY 2014 changes.

ICD-10-CM Conversion: In the FY 2015 IRF PPS final rule, CMS finalized conversions from the International Classification of Diseases, 9th Revision, Clinical Modification (ICD-9-CM) to the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for the IRF PPS, which will be effective when ICD-10-CM becomes the required medical data code set for use on Medicare claims and IRF PAI submissions. The implementation date for ICD-10-CM is October 1.

IRF-specific Market Basket: For FY 2016, CMS is finalizing an IRF-specific market basket to replace the Rehabilitation, Psychiatric and Long-Term Care market basket. The IRF market basket is based on 2012 data (the RPL market basket is based on 2008 data). The IRF market basket is derived from using both freestanding and hospital-based IRF Medicare cost report data from FY 2012.

Changes to the Wage Index: CMS finalized its proposal for transitioning to the wage index associated with the new Office of Management and Budget delineations without any modifications. A one-year blended wage index will be provided for all IRFs, and a three-year phase-out of the rural adjustment for IRFs that were deemed rural in FY 2015 but are considered urban under the new delineations. CMS will apply the one year blended wage index in FY 2016 for all geographic areas, to assist IRFs in adapting to these changes.

  • FY 2015 rural IRFs classified as urban in FY 2016 will receive two-thirds of the FY 2015 rural adjustment in FY 2016, as well as the blended wage index.
  • For FY 2017, these IRFs will receive the full FY 2017 wage index and one-third of the FY 2015 rural adjustment.
  • For FY 2018, these IRFs will receive the full FY 2018 wage index without a rural adjustment.

Changes to the IRF Quality Reporting Program (QRP): The Improving Medicare Post-Acute Care Transformation Act of 2014 (“IMPACT” Act) added Section 1899B to the Social Security Act (the Act) to require that IRFs report data on measures that satisfy measure domains specified in the Act. These same measures are to be implemented in long-term care hospitals, IRFs, skilled nursing facilities and home health agencies. This final rule adopts measures that satisfy three of the quality domains required by the IMPACT Act in FY 2016: skin integrity and changes in skin integrity; functional status, cognitive function, and changes in function and cognitive function; and incidence of major falls. IRFs that fail to submit the required quality data to CMS will be subject to a 2 percentage point reduction to their applicable FY annual increase factor.

Finalized Changes:

The domains specified by the IMPACT Act, and the quality measures finalized, are as follows:

  • Domain 1: Skin integrity and changes in skin integrity:
    • Quality Measure: “Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened” (NQF #0678)
  • Domain 2: Functional status, cognitive function, and changes in function and cognitive function:
    • Quality Measure: Application of the “Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function” (NQF #2631; Endorsed on July 23, 2015)
  • Domain 3: Incidence of major falls:
    • Quality Measure: Application of the “Percent of Residents Experiencing One or More Falls with Major Injury” (NQF #0674)

In addition to the measures listed above, CMS adopted four additional functional status quality measures, and completed the previously finalized quality measure “All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from Inpatient Rehabilitation Facilities” (NQF #2502), in order to establish its newly NQF-endorsed status.

Additionally, CMS will begin publically reporting IRF quality data in the fall of 2016. This includes a 30-day period for review and correction of quality data prior to public display.

Finally, CMS is temporarily suspending their previously finalized data validation policy in order to allow time to develop a more comprehensive policy that will potentially decrease the burden on IRF providers, allow CMS the ability to establish an estimation of accuracy related to quality data submitted to them, and facilitate the alignment of the IRF validation policy with that of other CMS quality reporting programs policies.

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