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Tags Posts tagged with "IRF"

IRF

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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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The Centers for Medicare and Medicaid Services (CMS) finalized the fiscal year (FY) 2026 inpatient rehabilitation facility (IRF) payment rule and published it in today’s Federal Register.

The final rule is a fairly straightforward payment and coverage rule, similar to the April 2025 proposed rule. The payment and IRF Quality Reporting Program (IRF QRP) updates are outlined below.

Payment: CMS expects an aggregate increase of $340 million in payments to IRFs across the PPS. This reflects an increase of approximately 2.6% in estimated payments, including all relevant adjustments.

Quality Reporting Program (QRP):

  • CMS finalized the removal of two quality measures: (1) the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, beginning with the FY 2026 IRF QRP, and (2) the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure, beginning with the FY 2028 IRF QRP. IRFs will continue to have the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure data collection item in the IRF-PAI until October 1, 2026, with CMS making the data collection voluntary and removing Q4 2025 data for this measure from the FY 2027 IRF QRP Compliance Determinations. CMS took similar action in other recently finalized payment rules. CMS also finalized their proposals to end the public display of these measures following the September 2025 Care Compare refresh.
  • CMS finalized the removal of four Standardized Patient Assessment Data Elements (SPADEs) under the Social Determinant of Health (SDOH) category with the FY 2028 IRF QRP, specifically: Living Situation (R0310), Food (R0320A and R0320B), and Utilities (R0330).
  • CMS finalized its procedural and review-focused changes to the IRF QRP reconsideration process. First, CMS will permit IRFs to request, and CMS to grant, an extension to file a request for reconsideration of a non-compliance determination if, during the 30-day period to request a reconsideration, the IRF was affected by an extraordinary circumstance beyond the control of the IRF (for example, a natural or man-made disaster). Second, CMS is finalizing its proposed updates to the bases on which CMS can grant a reconsideration request, providing that CMS will grant a timely request for reconsideration, and reverse an initial finding of non-compliance, only if CMS determines that the IRF was in full compliance with the IRF QRP requirements for the applicable program year.
  • CMS noted that it received extensive feedback on its Requests for Information (RFI) in four separate domains: (1) future measure concepts for the IRF QRP; (2) potential revisions to the IRF Patient Assessment Instrument (IRF-PAI); (3) potential revisions to the data submission deadlines for assessment data collected for the IRF QRP; and (4) advancing digital quality measurement in IRFs.

Requests for Information:
The rule included four dedicated Requests for Information (RFI) related to the IRF QRP and IRF-PAI. The final rule summarized the comments they received on these topics but did not offer any commentary on what CMS plans to do in future work in these areas.

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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

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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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NOTE TO INSPECTOR: The word "iridium" on the pen's nib is not a brand: it's the name of the metal of which the nib is made. Thanks. Inky old fountain pen on a $100 bill.

The Medicare Payment Advisory Commission (MedPAC) held their regular public meeting on January 16 – 17, 2025. During one of their presentations, “Assessing Payment Adequacy and Updating Payments: Skilled Nursing Facility Services; Home Health Agency Services; Inpatient Rehabilitation Facility Services; Outpatient Dialysis Services; and Hospice Services,” there was a draft recommendation specific to inpatient rehabilitation facilities (IRF). The draft recommendation was for fiscal year 2026 and noted that Congress should reduce the 2025 Medicare base payment rate by 7 percent. The PowerPoint presentation is available here.

During this public meeting, MedPAC voted to finalize this recommended payment reduction to fiscal year 2026 IRF Prospective Payment System (PPS) payments. Both AMRPA and other national hospital stakeholders, on behalf of IRFs, strongly opposed this proposed payment cut (prior to the public meeting). However, MedPAC advanced the recommended cut with limited discussion about the potential impacts on patient access and IRF operations.

MedPAC’s recommendations do require Congressional action. As a result, advocacy will be planned to continue to voice concerns with this recommendation. Members will be kept apprised of any upcoming changes.

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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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The Centers for Medicare and Medicaid Services (CMS) issued a Memorandum entitled, “Updates to the Condition of Participation (CoP) Requirements for Hospitals and Critical Access Hospitals (CAHs) to Report Acute Respiratory Illnesses,” back in October 2024. This memorandum provided updates and clarifications to the ‎Respiratory Reporting Requirements included in the FY 2025 Inpatient Prospective Payment System ‎‎(CMS-1808-F) Final Rule in the Federal Register (89 FR 68986).‎

The Memorandum provides guidance indicating that “Psychiatric Hospitals, Rehabilitation Hospitals, ‎Psychiatric Hospital Distinct Part Units, and Rehabilitation Hospital Distinct Part Units will report ‎once, annually, beginning in January, and only include the data for the previous week.”‎

The Memorandum also provides guidance on what the information collection will require:

  • One-Day-a-Week Snapshot
    • Staffed bed capacity and occupancy including adult and pediatric
    • Hospitalizations prevalence by respiratory illness and bed type
  • Weekly Total New Hospital Admissions
    • Total new hospital admissions for adult and pediatric patients by age range, over a defined weekly period

Additional information regarding the Hospital Respiratory Reporting requirements are also available on the Hospital Respiratory Data web page of the Centers for Disease and Prevention (CDC) website. The CDC will also be making changes to the reporting protocol and training information based ‎upon this modification in requirements.‎

Members are encouraged to closely review both the Memorandum from CMS and the information on the reporting requirements posted on the CDC website.

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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.

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On April 24, 2024, Novitas Solutions hosted their first webinar for inpatient rehabilitation facilities (IRF) in preparation for the start date of the IRF Review Choice Demonstration (RCD) in Pennsylvania on June 17, 2024. Novitas is the RCD contractor for the state of Pennsylvania. The webinar provided an overview of the process, the different review choices, and the instructions for contractor-specific portal (Novitasphere). While the webinar primarily covered the basics of the program as previously laid out in CMS’s materials, there was some new information that was shared:

  1. For the first time, Novitas introduced the clinical leadership team for the demonstration in Pennsylvania:
    • Ene Ojile, the Contract Medical Director overseeing the RCD in Pennsylvania. Dr. Ojile is Board-Certified in Physical Medicine & Rehabilitation (PM&R), and she most recently served as Medical Director for a large freestanding inpatient rehabilitation hospital.
    • Jessica Hicks, RN, MSN, the Medical Review Manager.
    • Mia Jackson, RN, BSN, the Medical Review Team.
  2. There was some discussion and confusion about the methodology Novitas will use to calculate individual hospital’s affirmation rates under the RCD. During the webinar, Novitas staff stated that the total number of submissions and resubmissions would be included in the calculation, potentially penalizing hospitals for completing resubmissions even if the claim is eventually affirmed. After the webinar, Novitas circulated a “clarification” indicating that, “The number of resubmissions is not counted against the affirmation rate.” Additional clarification will be requested to confirm how the rates will be calculated and that the same methodology will be used as in Alabama.

The slides from the April 24 webinar are now available, and Novitas has also posted a recording of the main presentation (without the public Q&A portion) available here.

Novitas will also be hosting the following training and education webinars leading up to the start date. You can register for these webinars at their website.

  • May 2 — Review Choice Selection & Process (PA IRF Providers Only)
  • May 3 — RCD: How to Prepare (All JH and JL IRF Providers)
  • June 4 — Pre-Claim and Post-Payment Review Submissions (PA IRF Providers Only)
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