IRF Count Down Continues: Are You Ready?

IRF countdown is the change to use quality indicators for CMG payment calculation.

The final rule for FY 2019 for Inpatient Rehabilitation Facility (IRF) payment included provisions to remove the Functional Independence Measure (FIMtm) from the IRF-PAI (Patient Assessment Instrument) and incorporate certain data elements from the Quality Indicators section of the IRF-PAI into the case-mix classification system to assign patients to a case mix group (CMG). 

As the transition date of Oct. 1, 2019 approaches, IRFs need to be finalizing preparation and training for the change.

As IRFs continue to plan, there are a number of items that should be addressed.

Timing is Everything
The change applies to discharges occurring on or after Oct. 1, 2019.  IRFs should continue to collect both Quality Indicator and FIM data for patients who will be discharged around the transition date to ensure that adequate data is documented and available to support billing.

It’s Not Just “Take Away One Set of Scores”
While it might be easy to become complacent and take the approach of “we’ll just stop collecting one set of data,” organizations need to address both the processes and individual provider behaviors related to scoring the Quality Indicators. While the scoring definitions may be similar, the process is very different. tm admission,

In some cases, the assessment could take up to three days (stair-climbing and car transfers are good examples), but in other cases, the assessment might be completed on the day of admission (rolling right and left in bed is a good example). Organizations need to determine when interventions for improvement begin, and how and when to determine that the assessment has been completed and therapeutic interventions have begun. Once these discussions and decisions have been made, documentation templates can be developed or revised to reflect the new practice.

Process Change Will Support Success
Because of the different perspective on assessment to identify baseline patient performance versus the “best” or “worst” performance, process changes may be necessary. Providers may wish to script how assessments are approached and standardize how they complete evaluations and initial scoring. This is particularly true for therapy services when mobility and activities of daily living (ADL) are being assessed. Communication between nursing and therapy will be essential in determining the most accurate baseline score.

Training Remains Key
CMS continues to provide online and in-person training related to the Quality Indicators. Continuous education and training of key stakeholders within each organization essential and IRFs should take advantage of these sessions as well as identify an internal expert to provide ongoing training and monitoring.

Ongoing Audits Will Ensure Success
Accurate completion of the Quality Indicator scores is essential for both payment and outcomes monitoring for any IRF. Implementing internal audits – both peer audits and self-audits – can assist an IRF in a successful transition.

What’s the Bottom Line?
The clock is ticking! With six months left before the full transition, IRFs should evaluate their current practices and determine needs for template revisions, process changes, and training.


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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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