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Tags Posts tagged with "IRF"

IRF

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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)

The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2025 hospital inpatient prospective payment system (IPPS) proposed rule. While the proposed rule is focused primarily on provisions specific to acute care hospitals and long-term care hospitals (LTCH), the rule includes a proposed mandatory model — the Transforming Episode Accountability Model (TEAM) — that would implement episode-based payments for five procedures: lower extremity joint replacement, surgical hip femur fracture treatment, spinal fusion, coronary artery bypass graft, and major bowel procedure.

Under the proposed program, selected acute care hospitals would coordinate care for fee-for-service (FFS) beneficiaries who undergo one of the listed procedures and assume responsibility for the cost and quality of care through the first 30 days after the Medicare beneficiary leaves the hospital. Hospitals required to participate would continue to bill Medicare FFS but would receive a target price based on all non-excluded Medicare Parts A & B items and services included in an episode; inpatient rehabilitation facility (IRF) care is listed among these covered services. Hospitals may earn a payment from CMS, subject to a quality performance adjustment, if their spending is below the target price (additionally, hospitals could owe CMS a repayment amount, subject to a quality performance adjustment, if their spending was above the target price). Hospitals will face a “graduated risk” scale through different participation tracks to allow participants to ease into full-risk participation.

Per CMS, the program aims to incentivize coordination between care providers during surgery, as well as the services provided during the 30 days that follow, and require referral to primary care services to support continuity of care. CMS notes that TEAM hospitals may “want to engage in financial arrangements with providers and suppliers or participants in Medicare Accountable Care Organization (ACO) initiatives who are making contributions to the TEAM participant’s performance in the model,” and TEAM hospitals could share reconciliation payment amounts or repayment amounts with these individuals and entities. IRFs are listed among the potential “TEAM Collaborators” by CMS. Comments are encouraged on both the proposed definition of a TEAM collaborator and their role in the model.

There are several other provisions notable for IRFs, including the fact that CMS is proposing to require that TEAM hospitals “must, as part of discharge planning, account for potential financial bias by providing TEAM beneficiaries with a complete list of all available post-acute care options in the Medicare program, including home health agencies (HHA), skilled nursing facilities (SNF), IRFs, or LTCHs, in the service area consistent with medical need, including beneficiary cost-sharing and quality information (where available and when applicable).” The list must also indicate whether the TEAM participant has a sharing arrangement with the post-acute care provider.

The model would begin in 2026 and run for five years and is intended to build on other episode-based models, such as the Bundled Payments for Care Improvement Advanced and Comprehensive Care for Joint Replacement Models. Like with other Center for Medicare and Medicaid Innovation (CMMI) programs, CMS will assess whether the model would reduce Medicare spending while maintaining or improving the quality of care.

The proposed rule will be published in the May 2, 2024, Federal Register and will be open for public comments.

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The next phase of the Centers for Medicare and Medicaid Services (CMS) inpatient rehabilitation facility (IRF) review choice demonstration (RCD) is scheduled to be implemented in Pennsylvania on June 17, 2024, and will last for five years. This demonstration applies to only IRF providers physically located in Pennsylvania.

Between May 3, 2024, and June 2, 2024, IRFs must select either 100% pre-claim review or 100% post-payment claim review.

CMS has stated that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. This program reduces the number of Medicare appeals, improves provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

Novitas Solutions is the Medicare Administrative Contractor (MAC) for Pennsylvania and will process the IRF claims. In preparation for the implementation of IRF RCD, Novitas Solutions will be conducting their first webinar on April 24, 2024, from 1:00 pm – 2:30 pm. Registration to participate in this webinar is now open. Members are strongly encouraged to participate in this webinar to prepare for this demonstration. If the registration link does not work, please copy and paste the below link into your browser to register:
https://fcso.webex.com/webappng/sites/fcso/meeting/register/0fd87e2111f7446fa477d0a25f78674c?ticket=4832534b000000073a942d9e6f94601b6b106adc8f502bcee359653432e8c326edb0f50ebc253329&timestamp=1711559626291&RGID=re6663754d2fe70defe3195e29c69465a

In addition to information on the CMS website, Novitas Solutions has a dedicated website that provides a great deal of information and resources on IRF RCD.

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In order to avoid a potential 2 percent decrease in the annual payment update for fiscal year (FY) 2025 (October 2024 – September 2025), inpatient rehabilitation facilities (IRF) are reminded that they must submit complete data in calendar year (CY) 2023 for all quality measures that are a part of the IRF Quality Reporting Program (QRP).

IRF Patient Assessment Instrument (IRF-PAI) assessment data and data submitted via the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN) for July 1 – September 30 (Q3) of calendar year 2023 must be submitted no later than 11:59 pm on February 15, 2024.

The Centers for Medicare and Medicaid Services (CMS) contractor Swingtech sends informational messages to IRFs that are not meeting Annual Increase Factor (AIF) thresholds on a quarterly basis ahead of each submission deadline. These messages were sent late last week. IRFs are encouraged to check to see if any members of their QRP team received a message from the email address “[email protected].” If members need to add or change the email addresses to which these messages are sent, please email QRP Help and be sure to include your facility name and CCN along with any requested email updates. Any IRFs who receive a Swingtech email message are encouraged to identify and review the measures stated as missing data for Q3 2023 ASAP, and resolve any data issues by the February 15 deadline.

Image by StockSnap from Pixabay

The Centers for Medicare and Medicaid Services (CMS) has released a short, animated explainer video, “Social Determinants of Health Items: Determining When a Proxy Response is Allowed,” for inpatient rehabilitation facilities (IRF), home health (HH), and long-term care hospital (LTCH) providers. CMS developed this video to assist providers in accurately determining when the use of a proxy response is allowed for the following Social Determinants of Health (SDoH) items: A1005. Ethnicity, A1010. Race, A1110. Language, A1250. Transportation, B1300. Health Literacy, and D0700. Social Isolation.

If you have questions about accessing the resources or feedback regarding the trainings, please email the PAC Training Inbox. Content-related questions should be submitted to the HH QRP Help Desk, IRF QRP Help Desk, or the LTCH QRP Help Desk.

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The Centers for Medicare and Medicaid Services (CMS) has released a number of additional and updated documents related to the inpatient rehabilitation facility (IRF) review choice demonstration (RCD). Included in these documents are:

  • An updated and revised Operational Guide — Clarifies key programmatic details regarding the different review choices and other facets of the demonstration.
  • Frequently Asked Questions Document — The FAQ focuses on major areas of confusion on the choice selection and submission processes, the Pre-Claim Review Track, and medical necessity determinations.
  • Transcript and Recording — From the June 27, 2023, special open-door forum on the IRF RCD.

Additional information about the IRF RCD can be found on the CMS IRF RCD web page.

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The Centers for Medicare and Medicaid Services (CMS) conducted a special open door forum on June 27, 2023, that focused on the Review Choice Demonstration (RCD) for inpatient rehabilitation facilities (IRF). Beginning August 21, 2023, the RCD will begin for IRF services in Alabama. CMS has shared that IRFs in Pennsylvania will be included in the next phase of the demonstration. For additional information, there is an RCD web page dedicated to this. The presentation from the June 27 special open door is also available.

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The Centers for Medicare and Medicaid Services (CMS) recently notified the American Medical Rehabilitation Providers Association (AMRPA) that the rollout of the Review Choice Demonstration (RCD) would begin on August 21, 2023, in Alabama. In previous information released about the RCD, Pennsylvania is most likely to be one of the next states in line for this rollout. Under this demonstration, CMS Medicare Administrative Contractors (MACs) will review all Medicare Fee-for-Service (FFS) claims in select states. CMS will utilize a dedicated website to provide updated information and resources to inpatient rehabilitation facility (IRF) stakeholders.

RCPA is working closely with AMRPA staff and will keep members apprised of developments and updates throughout the demonstration. The RCD website confirms that affected IRFs will have the option to elect pre-claim or post-payment review (and must use the same option for all claims).

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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.