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  • IRFs Receive 2.5% Increase From CMS in FY 2020; Additional Reporting Requirements in FY 2022

    In a final rule from the US Centers for Medicare and Medicaid (CMS), inpatient rehabilitation facilities (IRFs) will see a 2.5% payment increase in the 2020 fiscal year (FY), which begins October 1, 2019—an approximate boost of $210 million. But they'll also need to prepare for some expanded reporting measures in the years to come—including a requirement to report data on social determinants of health.

    Reporting requirements won’t change much in FY 2020. However, beginning with the FY 2022 IRF Quality Reporting Program (QRP), IRFs will be required to provide certain standardized patient assessment data (SPADE) to CMS. The additional SPADE requirements are aimed at bringing IRFs up to speed with provisions of the 2014 IMPACT Act, a law that mandated more uniformity in reporting across postacute care (PAC) settings. In a fact sheet on the final rule, CMS writes that the addition of these SPADES "will improve coordination of care and enable communication."

    Specifically, CMS will adopt the SPADES on pain interference on sleep, therapy, and day-to-day activities, provisions being added in light of the opioid crisis. CMS is considering adding future SPADEs including dementia, bladder and bowel continence, care preferences, advance care directives and goals of care, caregiver status, veteran status, health disparities and risk factors, and sexual orientation. Also on CMS' radar: assessments related to opioid use, and frequency, exchange of electronic health data, and interoperability.

    Beginning in FY 2022, IRFs will be required to report patient data on admissions and discharges dating back to October 1, 2020, in the following areas: cognitive function and mental status; special services, treatments, and interventions; medical conditions and comorbidity; impairment; and a new category—social determinants of health (SDOH). IRFs have been reporting on some components of these areas since 2018, mostly related to function, pressure wounds, and skin integrity.

    To gather cognitive function and mental status data, IRFs will be now required to use the standardized items of Brief Interview for Mental Status (BIMS) and Confusion Assessment Method (CAM). APTA supported these in its comments but advised caution, expressing concerns that the assessments aren't sensitive enough to pick up mild-to-moderate cognitive impairments. The new SDOH would gather data on race, ethnicity, preferred language, interpreter services, health literacy, transportation, and social isolation—factors that CMS writes "[have] been shown to impact care use, cost, and outcomes for Medicare beneficiaries."

    CMS also finalized 2 new process measures; one having to do with whether a provider receives a current reconciled medication list at discharge or transfer, and another relating to whether the patient, family, or caregiver receives a similar list upon discharge from a PAC setting.

    Among other elements of the final rule:

    CMS backs away from weighted motor score. While CMS had proposed to use a weighted motor score to assign patients to case mix groups, it finalized the use of an unweighted motor score starting in FY 2020 “to ease providers’ transition to the use of the quality indicator data items for payment purposes beginning on October 1, 2019.” APTA had expressed in its comments concern about moving to a weighted motor score, specifically about the de-emphasis on patient mobility and that the proposed motor score weight index may compromise access to physical therapy in the IRF setting.

    The compliant IRF list is gone. CMS will stop publishing a list of IRFs that successfully met reporting requirements on its Inpatient Rehabilitation Facility Quality Reporting Program website.

    Reporting for some baseline nursing facility residents will decrease. Specifications of the discharge-to-community PAC measure would be altered to exclude baseline nursing facility residents.

    IRFs will make the call on who's considered a "rehabilitation physician." The final rule will loosen the definition of "rehabilitation physician," allowing individual IRFs to establish their own definitions.

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