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Tags Posts tagged with "Quality Reporting Program"

Quality Reporting Program

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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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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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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.

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Late yesterday, the Centers for Medicare and Medicaid Services (CMS) issued the fiscal year (FY) 2024 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.

The proposed rule includes a 3.7 percent payment increase, compared to the 3.9 percent payment update that CMS finalized for FY 2023. This payment update reflects the effects of the proposed IRF market basket update for FY 2024 of 3.0 percent, which is based on the proposed IRF market basket increase factor (3.2 percent), productivity adjustment (0.2 percent), and outlier payment increase (0.7 percent).
** Please note that these figures are subject to change in the final rule if updated forecasts become available, which typically occurs.

CMS is making a number of changes to the Quality Reporting Program (QRP), including the future addition of a discharge function score measure and patient-level COVID vaccination measure as well as a modification of the current healthcare personnel COVID-19 vaccination measure to reflect the latest vaccination recommendations.

In addition, CMS is proposing to allow hospitals to open a new IRF unit and begin being paid under the IRF PPS at any time during the cost reporting period (rather than the current restrictive enrollment rules). The proposed rule does not address any of the COVID-19 PHE waivers, including the three-hour rule and virtual team conferences, nor does it include any further discussion of the expanded transfer policy (to include certain discharges under the care of home health) that was the subject of a Request for Information (RFI) in last year’s rule.

A more detailed and extensive summary of the proposed rule will be forthcoming.

The proposed rule will be published in the Federal Register for April 7, 2023. Comments on the proposed rule will be considered until 5:00 pm on June 2, 2023. For additional information, CMS also released a fact sheet.

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The Centers for Medicare and Medicaid Services (CMS) has created short videos and developed patient cue cards to assist providers with learning how to code patient assessment instruments for the following Post-Acute Care (PAC) Quality Reporting Programs (QRP):

Help LTCH, IRF, and HH patients select responses by showing them the new cue cards for:

See LTCH, IRF, HH, and SNF Quality Reporting Program Training for more information.

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