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  • CMS Wants to Drop Functional Measure, 2 Quality Reporting Measures From IRF Requirements

    The US Centers for Medicare and Medicaid (CMS) is continuing its trend toward easing administrative burdens and eliminating what it believes may be duplicative quality-reporting activities—this time, by way of a proposed rule for inpatient rehabilitation facility (IRF) payment that would do away with a longstanding functional assessment and 2 outcome measures.

    The assessment slated for possible elimination is the Functional Independence Measure (FIM), part of the IRF Patient Assessment Instrument. According to a CMS fact sheet on the proposed rule, data collected through the FIM are being captured in other parts of the assessment instrument. The use of the FIM dates back to 1987; its use would end October 1, 2019.

    Also up for possible elimination: measures related to methicillin resistant staph aureus (MRSA) infection and the percent of patients assessed and given the seasonal flu vaccine. CMS describes both measures as ones in which costs of reporting outweigh the benefits. The reporting changes would be implemented October 1, 2018.

    Other changes in the proposed rule include:

    • A 0.9% payment increase for FY 2019—about the same percentage increase as in 2018
    • Elimination of reporting requirements related to the rehabilitation physician conducting team meetings remotely
    • Allowance for the postadmission physician evaluation to count as one of the required face-to-face physician visits
    • Removal of requirements for admission order documentation—but not the requirement for admission orders themselves

    Also included in the proposed rule is a general call for feedback on several topics, including ideas for achieving better electronic sharing of data between providers, the possibility of allowing the rehabilitation physician to determine whether a particular patient assessment could be conducted remotely, the training of nonphysician providers relevant to IRFs, and ways that nonphysician IRF provider roles could be expanded.

    APTA will submit comments on the proposed rule by the June 26 deadline.


    • I agree with getting rid of the FIM. The admission and discharge caretool is adequate for rehab measures.

      Posted by Julie Reeder on 5/25/2018 10:28 PM

    • Yes Eliminate the FIM. The dim at discharge is the proper tool n suffices !

      Posted by Salrehab on 3/14/2019 11:15 AM

    • What are other ways to do outcome measures in a rehab setting? Can you guys help me with specific test names that you use at your rehab centers? For example, what is the admission and discharge caretool? what is the dim? what does it stand for? what does it include?

      Posted by Carolain on 4/17/2019 12:02 PM

    • Does this mean that the CMS-QI scale needs to be completed daily by the therapists similar to how the FIM is recorded now?

      Posted by Janae on 6/25/2019 4:03 PM

    • @Janaie: Thanks for the question! CMS began collecting patient assessment items in the Quality Indicators Section of the IRF-PAI on October 1, 2016. As these data items are collected for all IRFs, CMS determined that collection of the FIM data was duplicative and created an undue burden. As such, the FIM items will be removed from the IRF-PAI and replaced with the Quality Indicators beginning October 1, 2019. The data items being collected in the quality indicators section of the IRF-PAI also will be incorporated into the IRF PPS for payment purposes. Admission and discharge IRF-PAI items must be completed before data records are transmitted to CMS. Information and resources on how to complete the IRF-PAI can be found here under Downloads: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/IRF-Quality-Reporting/IRF-PAI-and-IRF-QRP-Manual.html.CMS has indicated they will continue to provide training and educational resources on the quality indicators prior to the effective date of October 1, 2019. Questions related to the quality indicators, IRF QRP requirements, etc. may be submitted to CMS at: IRF.Questions@cms.hhs.gov.

      Posted by APTA Staff on 6/27/2019 8:17 AM

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