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Tags Posts tagged with "Inpatient Rehabilitation Facility"

Inpatient Rehabilitation Facility

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2027 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

The proposed rule includes some technical proposals that would modify the IRF coverage and documentation requirements as well as IRF QRP submission deadlines. The proposed rule does not include any proposals to modify the existing IRF transfer policy. The proposed rule does, however, include several Requests for Information (RFI) that could indicate potential future impactful changes.

On the FY 2027 payment side, the rule would provide an overall 2.8% increase to estimated payments per discharge, compared to the 2.6% payment update that CMS finalized for FY 2026.


FY 2027 Payment Updates

  • Aggregate Estimated Payment Increase: 2.8% / $355 million (field-wide)
  • Market Basket Update (with Productivity Adjustment): 2.4%
  • Labor-Related Share: 74.5%
  • Standard Payment Conversion Factor: $19,881
  • Outlier Threshold: $8,689 (from $10,141 in FY 2026)

FY 2027 Coverage, Payment, and Documentation Policy Changes

Initiation of Therapy Requirement
CMS proposes to clarify the requirement that therapy be initiated within 36 hours of midnight of the day of admission to the IRF.

Documenting Function in Preadmission Screen
CMS proposes to expand the elements required in the preadmission screening (PAS) to include “current functional status” as well as prior level of function.

Timing of Interdisciplinary Team Meeting
CMS proposes to tighten the requirement for the timing of the weekly interdisciplinary team meeting by requiring an initial interdisciplinary team meeting to occur “on or before the fourth day from midnight on the date the patient is admitted” and subsequent team meetings to occur “at least once per week after the date of the prior team meeting.”

Request for Information on Future IRF Payment Reform
The rule includes an extensive Request for Information (RFI) on future IRF payment reform, specifically two major areas of reform:

  1. Refining the current IRF patient classification system by creating a draft list of IRF-specific clinical categories; and
  2. Creating a new system of comorbidity scoring to better account for the severity and number of comorbidities for IRF patients.

The RFI does not propose any of these changes be implemented in FY 2027 but requests stakeholder feedback on both areas. CMS also references two new technical reports addressing their PPS changes under consideration; these are available for download as part of the rule’s associated data files here.


FY 2027 Quality Reporting Program Updates

Proposal to Revise Data Submission Deadlines for the IRF QRP
For the FY 2029 IRF QRP, which will be based upon Calendar Year 2027 data, CMS is proposing to reduce this timeline to the “15th day of the second month following the end of calendar quarter.”


The proposed rule will be published in the Federal Register on April 6, 2026. Comments on the proposed rule are due by June 1, 2026.

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Inpatient rehabilitation facilities (IRF) are reminded, as part of the Hospital Conditions of Participation (CoP), that one week of information must be submitted to the Centers for Disease Control and Prevention’s National Healthcare Safety Network (CDC NHSN) portal related to certain respiratory conditions (COVID-19, Influenza, and RSV). This information must be submitted in January, as defined in the Protocol for the NHSN Hospital Respiratory Data (HRD) Reporting:

“To meet the annual reporting requirement, annual reporters should report data using either the HRD daily data pathway or HRD weekly data pathway for one of the following full weeks in January 2026:

  • Sunday, January 4, 2026 – Saturday January 10, 2026 (due by Tuesday January 13, 2025 – past due)
  • Sunday, January 11, 2026 – Saturday January 17, 2026 (due by Tuesday January 20, 2026 – past due)
  • Sunday, January 18, 2026 – Saturday January 24, 2026 (due by Tuesday January 27, 2026)
  • Sunday, January 25, 2026 – Saturday January 31, 2026 (due by Tuesday February 3, 2026)”

Additional information on the Respiratory Reporting Requirements is available here.

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The Centers for Medicare and Medicaid Services (CMS) recently published an errata document to the inpatient rehabilitation facility patient assessment instrument (IRF-PAI) Manual, Version 4.2, related to the coding of items J1750, J1800, and J1900. This errata document was issued to update guidance related to the Falls with Major Injury (FMI) measure in the IRF Quality Reporting Program (QRP), which is effective on January 1, 2026. Specifically, the guidance related to item J1900 Number of Falls Since Admission item has revisions to the definition of Injury (except Major) and Major Injury.

CMS also released the official Technical Specification Report for the Falls with Major Injury (FMI) measure. This report incorporates feedback received during the cross-setting Technical Expert Panel (TEP) held in May 2025. The report provides an overview of the measure, a high-level summary of the key features of the re-specified measure, a description of the methodology used to construct the FMI measure, and an overview of measure testing results. Additional guidance and related updates to the IRF-PAI Manual, Quality Measure Calculations and Reporting User’s Manual, and public reporting timelines will be provided at a future date. The report is available in the Downloads section on the IRF QRP Measures Information web page.

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At the December 4, 2025, Medicare Payment Advisory Commission (MedPAC) annual session on payment adequacy for Medicare providers, draft fiscal year (FY) 2027 payment recommendations were issued. The recommendations, “Assessing Payment Adequacy and Updating Payments: Inpatient Rehabilitation Facility (IRF) Services,” were shared. Included in their presentation were their findings on admissions, financial performance by IRF provider type, quality metrics, and other relevant data points. In addition to the payment-focused sessions, the meeting included a general session on post-acute care trends and “key issues,” which compared various patient- and payment-focused data across IRFs, skilled nursing facilities (SNF), and home health agencies (HHA).

During the IRF payment session, MedPAC advanced a draft recommendation calling for Congress to reduce the 2026 Medicare base payment rate for IRFs by 7 percent in FY 2027. This draft recommendation is identical to last year’s recommendation and marks an increase over the FY 2025 recommendation (a 5% cut to the Medicare base payment rate) and the FY 2024 finalized recommendation (3% cut).

MedPAC’s recommendations are advisory in nature, and most of MedPAC’s work can only be implemented via Congressional action. RCPA will monitor the status of these recommendations through close collaboration with the American Medical Rehabilitation Providers Association (AMRPA).

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The Centers for Medicare and Medicaid Services (CMS) has published the draft inpatient rehabilitation facility patient assessment instrument (IRF-PAI) version 4.4. This version of the IRF-PAI becomes effective on October 1, 2026.

This draft version has the following modifications from the current IRF-PAI Version 4.2:

  • IRF-PAI Item 8. Gender – has been moved to IRF-PAI Item A0810. Sex.
  • IRF-PAI Item 14. Admission Class – has been removed.
  • Transportation Item A1250 – has been modified into Transportation Item A1255 with new item verbiage and response options and is only to be collected at admission. Transportation item A1250 has been removed from the discharge assessment.
  • Item O0350. Patient’s COVID-19 vaccination is up to date – has been removed from the discharge assessment.

As finalized in the fiscal year (FY) 2026 Final Rule, draft version 4.4 also removes the Section R Social Needs items. The four items removed were social determinants of health (SDoH) data elements related to living situation, food, and utilities, which were previously scheduled to be implemented October 1, 2026.

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Novitas Solutions has released the Cycle 2 results for the inpatient rehabilitation facility (IRF) review choice demonstration (RCD). The Cycle 2 results letters were issued on September 10, 2025, and are available in Novitasphere.

IRFs will have a 2-week choice selection period for Cycle 3 from October 7, 2025 – October 20, 2025, using the Novitasphere portal.

Cycle 3 Choice Selection Options

If the approval rate meets or exceeds target affirmation rate of 85% for Cycle 2 (based on a minimum of 10 submitted pre-claim review requests or claims), the IRF may select 1 of the 3 subsequent review choices:

  • Choice 1: Pre-claim review (PCR)
  • Choice 3: Selective post-payment review (default if no review choice is made)
  • Choice 4: Spot check prepayment review

If the IRF’s affirmation or claim approval rate is less than the target affirmation rate or they have not submitted at least 10 requests/claims, the IRF must again choose from 1 of the initial 2 options:

  • Choice 1: Pre-claim review (PCR)
  • Choice 2: Post-payment review (default if no review choice is made)

Cycle Stats Reminder

IRFs can access information about their affirmation/approval rate at any given time during the current or previous review cycle through the Cycle Stats option in Novitasphere. Visit here for more information on cycle stats.

IRF RCD Questions

Questions or concerns regarding the IRF RCD should be directed to the IRF Customer Service line at 855-340-5975, Monday – Friday, 8:00 am – 6:00 pm.

IRF RCD Resources and Educational Opportunities

Visit the Inpatient Rehabilitation Facility (IRF) Review Choice Demonstration (RCD) web page for important information about the IRF RCD and upcoming educational events, including a recording of the September 24, 2025, webinar on IRF RCD: Cycle 2 Results and Transitioning to Cycle 3.

Important Deadlines

  • October 7, 2025 – October 20, 2025, Cycle 3 Choice Selection
  • November 1, 2025 – April 30, 2026, Cycle 3 Review Dates
  • On or before May 30, 2026, Cycle 3 Affirmation/Approval Rate Communication

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On September 24, 2025, WellSky will be conducting a webinar on the fiscal year (FY) 2026 inpatient rehabilitation facility prospective payment system (IRF PPS) final rule that was released by the Centers for Medicare and Medicaid Services (CMS) in early August. The webinar will begin at 12:00 pm. There is no cost to participate in this webinar.

Topics will include:

  • The key changes in the 2026 IRF Final Rule impacting reimbursement;
  • The technical changes and their indirect effects on your program;
  • The amendments to the QRP and the appeal process; and
  • The latest concerns about potential IRF reimbursement denials.

To participate in the webinar, register here.

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Last week, the Centers for Medicare and Medicaid Services (CMS) released the Fiscal Year (FY) 2026 Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) proposed rule, as well as an accompanying fact sheet. The rule does not include proposed changes to the IRF coverage requirements. On the payment side, the rule would provide an overall 2.8% increase to estimated payments per discharge, compared to the 2.5% payment update that CMS finalized for FY 2025. The rule is more substantive with respect to the future Quality Reporting Program (QRP) changes. Specifically, the rule proposes to remove certain quality measures and standardized patient assessment data elements (SPADE) implemented in recent years relating to COVID-19 vaccination and social determinants of health (SDOH), and to modify the process for reconsideration of IRF QRP non-compliance penalties. Finally, the rule includes various requests for information (RFI), soliciting feedback on the IRF QRP and IRF-Patient Assessment Instrument (PAI).

The proposed rule will be published in the Federal Register on April 30, 2025. RCPA will provide a more detailed overview of the proposed rule following this date. Comments on the rule are due to CMS by June 10, 2025.

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The Centers for Medicare and Medicaid Services (CMS) published and released a summary report from a recent inpatient rehabilitation facility (IRF) listening session that focused on revising the transmission schedule for the inpatient rehabilitation facility Patient Assessment Instrument (IRF-PAI).

The summary highlights the discussion about potential changes to the IRF-PAI transmission schedule for unplanned discharges as well as changes in payer source, providing the rationale for this discussion, and questions posed during the listening session. The listening session also discussed opportunities to improve the assessment and data collection for pediatric patients.

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WellSky will be offering a one-hour webinar entitled “60 Minutes With the IRF Final Rule” that will focus on the fiscal year (FY) 2025 Inpatient Rehabilitation Facility (IRF) Final Rule, which was finalized on July 31, 2024. It will go into effect October 1, 2024. As with past final rules, it will have a financial impact on reimbursement for IRFs as well as operational changes from both this final rule and past final rules going into effect. Join long-term care expert Jane Snecinski, FACHE, MRMC, MBA, for a live webinar and learn about:

  • The algorithm for IRF reimbursement (and key factors you should know);
  • The financial impact the rule will have on your IRF reimbursement;
  • Changes to the quality reporting factors; and
  • Changes included in previous years’ IRF final rules that may go into effect October 1, 2024.

The webinar is scheduled for September 18, 2024, from 12:00 pm – 1:00 pm ET. To participate in the webinar, register here.