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IRF

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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.

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Last week, H.R.8746 — Access to Inpatient Rehabilitation Therapy Act of 2022 was introduced to ensure Medicare beneficiaries in inpatient rehabilitation facilities (IRFs) are able to access all skilled, medically necessary rehabilitation therapies that are most appropriate for their condition. This bill, also known as the “three hour rule bill,” would expand the current three hour rule in which Medicare requires IRF patients to be able to participate in, and benefit from, three hours of rehabilitation therapy per day, five days a week (or 15 hours over a seven day period). The current regulation only allows physical therapy (PT), occupational therapy (OT), speech therapy, and orthotics and prosthetics care to count towards the three hour requirement. As a result, many patients have difficulty accessing additional forms of therapy that may be more appropriate.

During the COVID-19 public health emergency (PHE), the three hour rule has been waived in its entirety. If the Access to Inpatient Rehabilitation Therapy Act is enacted, it would ensure that IRFs maintain flexibility after the expiration of the PHE. Most importantly, the legislation would allow certain therapies, including recreational therapy, cognitive therapy, and respiratory therapy, to count towards the three hour rule after the patient’s admission. These additional therapies and skilled modalities would be identified by the Secretary of Health and Human Services (HHS). At the time of admission, the existing three hour rule would still apply, ensuring that IRF admissions do not increase (and thus add to underlying costs for the Medicare program) due to the new flexibility.

This legislative solution has been developed over several years with Members of Congress and a group of stakeholders, including the American Medical Rehabilitation Providers Association (AMRPA), the American Academy of Physical Medicine & Rehabilitation (AAPM&R), the Brain Injury Association of America (BIAA), and the American Therapeutic Recreation Association (ATRA).

For additional information, please refer to Congressman Courtney’s press release.

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On July 13, 2022, the Centers for Medicare and Medicaid Services’ (CMS) Medicare Administrative Contractors (MACs) distributed notifications to inpatient rehabilitation facilities (IRFs) that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for calendar year (CY) 2021, which will affect their FY 2023 Annual Payment Update (APU). Non-compliance notifications were placed into facilities’ “Certification and Survey Provider Enhance Reports” (CASPER) folders in the Quality Improvement and Evaluation System (QIES) for hospice and skilled nursing facilities (SNFs), and into facilities’ “My Reports” folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs and long-term care hospitals (LTCHs). If a facility received a letter of non-compliance, it may submit a request for reconsideration to CMS via email. The submission deadline is 11:59 pm on August 11, 2022. View the full details and instructions for submission here.

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The Centers for Medicare and Medicaid Services (CMS) recently issued updates associated with the inpatient rehabilitation facility (IRF) provider preview reports and the IRF Patient Assessment Instrument (PAI).

CMS has released the updated IRF Provider Preview Reports, which contain provider performance scores for quality measures and contain IRF-PAI data submitted by IRFs from Quarter 1 (Q1) 2021 through Quarter 4 (Q4) 2021, as well as CDC Clostridium Difficile (CDI) and Catheter-Associated Urinary Tract Infections (CAUTI) measures from Quarter 4 (Q4) 2020 through Quarter 3 (Q3) 2021, and Q4 2018 through Q1 2019 of the Healthcare Personnel (HCP) Influenza measure. The new HCP COVID-19 Vaccination Coverage measure will also be publicly reported on Care Compare in the September 2022 release and will reflect Q4 2021 data. Unlike prior September Care Compare refreshes, CMS will not be preforming the annual update to IRF claims-based measures, due to CMS only resuming the reporting of claims-based measures during the June 2022 refresh.

Providers have until July 15, 2022, to review their performance data. Providers can request CMS review their data during the preview period if they believe the scores are inaccurate. The final reports will be published on Care Compare and Provider Data Catalog during the September 2022 refresh of the website. Additional information is on the CMS IRF Quality Reporting Program (QRP) public reporting website.

CMS also published the IRF-PAI Quarterly Questions & Answers (Q&A) document that provides clarification to existing guidelines.

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The Centers for Medicare and Medicaid Services (CMS) has announced a virtual training program for both inpatient rehabilitation facilities (IRFs) and Long-Term Care Hospitals (LTCHs). The virtual IRF training program will review the updated guidance for the Inpatient Rehabilitation Facility – Patient Assessment Instrument (IRF-PAI) 4.0 and the LTCH Continuity Assessment Record and Evaluation (CARE) Data Set (LCDS) 5.0 for providers in the IRF and LTCH settings. This training is part of a comprehensive strategy to ensure IRF and LTCH providers have access to the education necessary to understand and comply with changes in reporting requirements associated with the IRF and LTCH Quality Reporting Programs (QRPs) that go into effect on October 1, 2022. A major focus of this training will be on the cross-setting implementation of the standardized patient assessment data elements being introduced in 2022 to ensure more consistent reporting and evaluation across post-acute care settings.

The training program consists of two parts:

  • Part 1: Beginning May 9, 2022: Access will be provided to recorded training session videos that deliver foundational knowledge necessary to understanding the new items and guidance. These videos are intended to be reviewed in advance of the live event.
  • Part 2: June 15–16, 2022: Live, virtual workshop sessions will provide coding practice on the items covered in the Part 1 videos. These live sessions will take place each day from 1:00 pm – 5:00 pm.

To participate in the training program, registration is required. If you have questions about accessing resources or feedback regarding the trainings, please email the PAC Training Mailbox. Content-related questions should be submitted to the LTCH QRP Help Desk and IRF QRP Help Desk

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The Centers for Medicare and Medicaid Services (CMS) recently released a revised Medicare Learning Network (MLN) resource, Medicare Payment Systems, to reflect the 2022 regulation changes to payment, quality, and policy for all health settings. These include acute care hospitals, inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs), home health, hospital outpatient, inpatient psychiatric facility, long-term care hospitals (LTCHs), ambulatory surgical centers (ASCs), and durable medical equipment, prosthetics, orthotics & supplies (DMEPOS).

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The Centers for Medicare and Medicaid Services (CMS) has released the updated Inpatient Rehabilitation Facility (IRF) Provider Preview Reports. These reports contain provider performance scores for quality measures and contain data submitted by IRFs from Quarter 3 (Q3) 2020 through Quarter 2 (Q2) 2021.

Providers have until February 25, 2022, to review their performance data. Providers can request CMS review their data during the preview period if they believe the scores are inaccurate. The final reports will be published on Care Compare and Provider Data Catalog (PDC) during the March 2022 refresh of the websites. For additional information, visit the CMS IRF QRP Public Reporting website.

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The Medicare Payment Advisory Committee (MedPAC) voted last week and unanimously recommended a five percent payment reduction for inpatient rehabilitation facilities (IRFs), skilled nursing facilities (SNFs), and home health agencies (HHAs). There was no additional feedback provided with this recommendation; however, additional information should be provided in their upcoming March 2022 report to Congress.

Also worth noting was that MedPAC discussed its mandated report related to designing a value incentive program (VIP) for post-acute care (PAC). This report is required under the Consolidated Appropriations Act of 2021, and this was the commission’s second session dedicated to development of the PAC VIP. The report is due to Congress by March 15, 2022. Due to the limited time to develop the report, MedPAC asserted it would not be making a formal recommendation in the March Report to Congress. Also during this session, MedPAC shared its plan to submit its separate report on a unified post-acute care payment prototype to Congress in 2023.

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The Centers for Medicare and Medicaid Services (CMS) has released a video tutorial for providers in Inpatient Rehabilitation Facilities (IRFs) with standardized data assessment guidance and assessment strategies for the cognitive assessment—known as the Brief Interview for Mental Status (BIMS). The video is approximately 22 minutes in length and is designed to provide targeted guidance for accurate coding by using live action patient scenarios.

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