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  • What's the Latest at CMS? Your Guide to Recent Proposed and Final CMS Rules

    The US Centers for Medicare and Medicaid Services (CMS) spent its spring and summer issuing proposed and final rules on areas ranging from the Medicare physician fee schedule, to what skilled nursing facilities will be paid and what they'll have to report, to inpatient reimbursement and home health episodes of care.

    Here's a quick guide to where some of these rules stand, and resources available from APTA—including an August 23 webinar focused on big changes CMS is eyeing for home health beginning in 2019 (11:30 am – 1:00 pm, ET). To register for the webinar email advocacy@apta.org.

    Medicare Physician Fee Schedule (MPFS)
    Status: Proposed; comments due September 11
    Resources: CMS fact sheet; PT in Motion News coverage
    The big news from the proposed MPFS for 2018 is that values for current procedural terminology (CPT) codes will be maintained—and a few even increased—after talk of the possibility that some of these codes were "misvalued." APTA is preparing comments on the proposed rule and has created a template letter for individual physical therapists (PTs) to send to CMS that covers both the proposed MPFS and more general Medicare issues.

    Home Health Prospective Payment System (HH PPS)
    Status: Proposed; comments due September 25
    Resources: CMS fact sheet; PT in Motion News coverage; August 23 webinar
    The fact that CMS will further reduce payment in 2018 by an estimated $80 million isn't exactly news—that cut is part of a series of reductions mandated by the Affordable Care Act (ACA). What is news is the CMS plan to reduce the unit of home health payments from 60-day to 30-day episodes of care, and to remove therapy service-use thresholds to make case-mix adjustments to HH payments in favor of "clinical characteristics and other patient information." Both of those changes would begin in 2019 under the proposed rule. APTA is preparing comments and is offering a webinar on August 23 from 11:30 am – 1:00 pm (ET) to outline the basics of the proposal and how to engage with CMS on the rule. To register for the webinar email advocacy@apta.org.

    Inpatient Prospective Payment System (IPPS)
    Status: Final; effective October 1, 2017
    Resources: APTA summary; CMS fact sheet; PT in Motion News coverage
    Acute care hospitals (ACHs) will see an estimated $2.4 billion increase in fiscal year 2018 (which begins October 1, 2017), while long-term care hospitals (LTCHs) will see a $110 million drop. Other highlights of the final rule include a CMS announcement that it will make medical record reviews a "low priority" when it comes to the requirement that physicians must certify that a patient admitted to a critical access hospital (CAH) will be discharged or transferred within 96 hours of admission, and the implementation of a 1-year moratorium on a policy that ties LTCH payment rates to ACH rates if an LTCH admits more than 25% of its patients from a single ACH. Another change: beginning in fiscal year 2019, CMS will include dual-eligibility status as a component in calculating penalties under the readmissions reduction program.

    Skilled nursing facility prospective payment system (SNF PPS)
    Status: Final; effective October 1, 2017
    Resources: APTA summary; CMS fact sheet; PT in Motion News coverage
    The final SNF PPS includes an overall 1% payment increase, changes to reporting requirements, and updates to the list of quality measures related to skin integrity, self-care, and mobility. CMS also will expand the window for its review of claims data related to potentially preventable 30-day readmissions. Previously CMS used a single year's worth of claims data; the rule expands that window to 2 years, an increase that CMS says will increase the number of SNFs with sufficient numbers of cases for public reporting.

    Inpatient Rehabilitation Facility Proposed Payment System (IRF PPS)
    Status: Final rule – effective October 1, 2017
    Resources: APTA summary, CMS fact sheet, PT in Motion News coverage
    Like SNFs, IRFs will see a 1.9% payment increase—about $75 million—for fiscal year 2018. The "60% rule"—a requirement that for an IRF to receive payment, 60% of its patients must require treatment for 1 or more of 13 conditions—has been adjusted to address diagnoses for patients with traumatic brain injury and hip fracture, as well as multiple trauma codes that didn't translate between ICD-9 and ICD-10. The new rule also requires IRFs to report standardized patient assessment data across 5 categories: functional status; cognitive functions; impairments; medical conditions and comorbidities; and special services, treatments, and interventions. Additionally, beginning in FY 2020, CMS will replace the current pressure ulcer measure with an updated version of the measure, an action that APTA supported in its comments.

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