CMS Releases IRF Final Rule for FY 2024

CMS Releases IRF Proposed Rule for FY 2024

On July 23, the Centers for Medicare & Medicaid Services (CMS) issued the Final Rule for Inpatient Rehabilitation Facilities (IRFs) that updates payment policies and the IRF Quality Reporting Program (QRP) requirements for the 2024 fiscal year (FY), and modifies the conditions for Excluded Units to allow hospitals to open a new IRF unit and begin being paid under the IRF Prospective Payment System (PPS) at any time during the cost reporting period. The rule is currently available for public inspection.

The major components are addressed below:

Updates to Payment Rates

Following standard methodology, CMS has finalized a 3.7-percent increase in overall IRF payments for an estimated $355 million increase in payments over the last FY. This increase is based on an update to the IRF PPS payment rates by 3.4 percent, based on the proposed IRF market basket update of 3.6 percent, less a 0.2-percentage point multi-factor productivity (MFP) adjustment. This brings the standard payment conversion factor for FY 2024 to $18,541.

The CMG payment Rate Table was adjusted to reflect this standard payment conversion factor.

Based on the usual calculations for setting the outlier threshold in order to maintain outlier payments equal to 3 percent of the estimated aggregate payments, the threshold was lowered to $10,423 for FY 2024.

Updates to Quality Reporting Program

For FY 2024, CMS is also adopting two new measures, modifying the measure related to Healthcare Personnel and COVID-19 Vaccine, and removing three measures. The agency said it will also begin public reporting of the Transfer of Health Information to the Provider and the Patient.

The new measure, beginning with FY 2025, would assess the percentage of IRF patients who meet or exceed a calculated expected discharge function score. The expected score is calculated based on mobility and self-care items already collected by the organization on the IRF-PAI (Patient Assessment Instrument). The measure would replace the current measure related to the percentage of patients with an admission and discharge functional assessment and care plan, as noted below.

Another new measure looks at IRF patient stays where patients are up to date with recommended COVID-19 vaccinations, in accordance with the Centers for Disease Control and Prevention’s (CDC’s) most recent guidance. Collection of this data would be via a new standardized item on the IRF-PAI.

The modification in the measure of COVID-19 Vaccine Coverage Among Healthcare Personnel will gauge what percentage of healthcare personnel (HCP) in IRFs who are considered up to date with recommended COVID-19 vaccination, in accordance with the CDC’s most recent guidance. Previously, IRFs reported only on whether HCPs had received the primary vaccination series for COVID-19. The modification would require IRFs to report the cumulative number of HCPs who are up to date with recommended COVID-19 vaccinations, in accordance with the CDC’s most recent guidance.

CMS said it will also remove the following functional outcomes measures:

  • The Application of Functional Assessment/Care Plan measure for Long Term Care patients;
  • The IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients; and
  • The IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients.

And finally:

Beginning with the September 2024 Care Compare Refresh or sooner, if possible, CMS will begin public reporting of the quality measure: Transfer of Health Information to the Provider and the Transfer of Health Information to the Patient.

This data is currently being collected and will be added to the public reporting data set. The measures report the percentage of patient stays with a discharge assessment indicating that a current reconciled medication list was provided to the subsequent provider or to patients or their families or caregivers at discharge or transfer.

Modifications to the Regulation for Excluded Inpatient Rehabilitation Facility Units Paid Under the IRF PPS

Prior regulations allowed hospitals to open a new Inpatient PPS (IPPS)-excluded unit only at the start of a cost reporting period. CMS noted in the Fact Sheet related to this Final Rule that “in order to make this change, hospitals must notify the CMS Regional Office and the Medicare Administrative Contractor (MAC) in writing at least 30 days before the date of the change and maintain the information needed to accurately determine the costs attributable to the IRF unit. Such a change would also remain in effect for the rest of the cost reporting period.”

Review the final rule here: Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2024 and Updates to the IRF Quality Reporting Program

Review the associated CMS fact sheet here: Fiscal Year 2024 Inpatient Rehabilitation Facility Prospective Payment System Proposed Rule (CMS-1781-F)

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Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

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