If a proposed rule from the US Centers for Medicare and Medicaid (CMS) is adopted as planned, 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 $195 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 (SDOH).
Reporting requirements wouldn't change much in fiscal year (FY) 2020 (beginning October 1, 2019). However, beginning with the FY 2022 IRF Quality Reporting Program (QRP), IRFs would 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.
Beginning in the 2022 fiscal year, IRFs would 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.
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 wants to introduce 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 proposed rule:
The compliant IRF list may go. CMS is proposing to stop publishing a list of compliant IRFs on the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) website.
Reporting for some baseline nursing facility residents would decrease. Specifications of the discharge-to-community PAC measure would be altered to exclude baseline nursing facility residents.
IRFs could make the call on who's considered a "rehabilitation physician." The proposed rule would loosen the definition of "rehabilitation physician," allowing individual IRFs to make the determination. At the same time, CMS is seeking comments on refining the definition in light of the proposed change.
As is typical, CMS is also seeking input on several areas not related to specific impending rule changes for FY 2020, including stakeholder comments on pain interference on sleep, therapy activities, and day-to-day activities—provisions that CMS is considering adding in light of the opioid crisis. The agency also seeks general feedback on possible additional SPADE data elements 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. Potential measures CMS would like feedback on include assessments related to opioid use, and frequency and exchange of electronic health data as well as interoperability.
APTA will submit comments on the proposed rule by the June 17 deadline. To weigh in on the proposed rule, check out APTA's regulatory "Take Action" webpage in the coming days for information on how and where to submit comments.