The Centers for Medicare & Medicaid Services (CMS) have released the Final Rule for Inpatient Rehabilitation Facilities (IRFs) on July 23. The new rule updates payment policies, IRF Quality Reporting Program (QRP) requirements for the 2024 fiscal year (FY), and modifies the conditions for Excluded Units. This allows hospitals to open a new IRF unit and start receiving payments under the IRF Prospective Payment System (PPS) at any time during the cost reporting period. The rule is now available for public inspection.
Below are the main components that have been addressed.
Updates to Payment Rates
Following established procedures, CMS has finalized a 3.7% increase in total IRF payments, amounting to a projected $355 million increase in payments over the previous FY. Based on the proposed IRF market basket update of 3.6 percent, less a 0.2 percentage point adjustment for multi-factor productivity (MFP), this increase is based on an update to the IRF PPS payment rates of 3.4 percent. The usual payment conversion factor for the fiscal year 2024 is now $18,541.
To reflect the standard payment conversion factor, the CMG payment Rate Table has been adjusted accordingly.
In order to maintain outlier payments equal to 3 percent of the estimated aggregate payments, the outlier threshold has been lowered to $10,423 for FY 2024, using the usual calculations.
Updates to Quality Reporting Program
CMS is implementing two new measures for FY 2024, modifying the measure related to Healthcare Personnel and COVID-19 Vaccine, and removing three measures. The agency has also announced that it will begin public reporting of the Transfer of Health Information to the Provider and the Patient. Starting from FY 2025, a new measure will assess the percentage of IRF patients who meet or exceed a calculated expected discharge function score. This 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 will replace the current measure related to the percentage of patients with an admission and discharge functional assessment and care plan. Additionally, a new measure will look 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. This data will be collected via a new standardized item on the IRF-PAI.
The modification in the measure of COVID-19 Vaccine Coverage among Healthcare Personnel will assess the 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 only reported on whether HCPs had received the primary vaccination series for COVID-19. With this modification, IRFs will now have to report the cumulative number of HCPs who are up to date with recommended COVID-19 vaccinations based on the CDC’s latest guidance.
CMS has announced the removal of the following functional outcomes measures for IRFs:
•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
•The IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients
Starting from the September 2024 Care Compare Refresh, or earlier if possible, CMS will publicly report the quality measure of Transfer of Health Information to the Provider and the Transfer of Health Information to the Patient. The data is currently being collected and will be added to the public reporting data set. These 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, their families, or caregivers at discharge or transfer.
The IRF PPS regulation for Excluded Inpatient Rehabilitation Facility Units has been modified.
Under the prior regulations, hospitals were only allowed to open a new Inpatient PPS (IPPS)-excluded unit at the beginning of a cost reporting period. However, CMS has made changes to this regulation. According to the Fact Sheet related to this Final Rule, hospitals can now make changes to their IPPS-excluded unit during the cost reporting period. 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 accurate information about the costs attributable to the IRF unit. Any changes made will remain in effect for the rest of the cost reporting period.