NEWS ALERT: CMS Posts 2020 IRF Proposed Rule

Proposed rule calls amending regulations clarifying the determination as to whether a physician qualifies as a rehabilitation physician is made by the IRF.

The Centers for Medicare & Medicaid Services (CMS) has issued a proposed rule for the inpatient rehabilitation facility (IRF) prospective payment system for the fiscal year 2020.

The proposal includes an estimated overall 2.5 percent increase factor that includes an IRF-specific market basket estimate of 3 percent less a .5 percent productivity adjustment. Additionally, CMS is proposing case mix group (CMG) revisions based on removal of Functional Independence Measure (FIMtm) scoring and use of Quality Indicator data for classification of patients into CMG groups.  Of note, CMS elected to weight the scores for functional indicators in determining placement in a CMG.

Updated Related to Quality Measures
The proposed rule also includes the following:

  • Two proposed additional Quality Measures both of which relate to Medication Reconciliation:
    • Transfer of Health Information to the Provider; and
    • Transfer of Health Information to the Patient.
  • Proposed adoption of a number of standardized patient assessment data elements (SPADEs).
  • These added data elements will assess cognitive function and mental status, special services, treatments and interventions, medical conditions and comorbidities, impairments, and social determinants of health (race and ethnicity, preferred language and interpreter services, health literacy, transportation, or social isolation).
  • Updates to the Discharge to Community IRF QRP measure
  • Removal of the published list of compliant IRFs from the IRF QRP website
  • Requirement to collect IRF-PAI data on all patients regardless of the patients’ payer

Additional Proposed Provisions
CMS is also proposing to amend the regulations to clarify that the determination as to whether a physician qualifies as a rehabilitation physician is made by the IRF.

Comments on the proposed rule will be accepted until June 17, 2019.

The proposed rule may be found at this link:

The proposed rule is expected to be published in the Federal Register on April 29, 2019.


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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