Proposed Changes to Quality Reporting for the 2019 Inpatient Rehabilitation Facility Prospective Payment System Rule

06/13/2018

The Proposed Rule for fiscal year (FY) 2019 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) proposes significant changes with regard to quality reporting for an IRF. The Centers for Medicare & Medicaid Services (CMS) propose to remove the Functional Independence Measure (FIM^TM) Instrument and associated function modifiers from the Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF PAI) in FY 2020. CMS proposes to replace the FIM^TM with function data collected pursuant to the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) known as Section GG, which the agency refers to as the data items from the Quality Indicators section of the IRF PAI, as the new basis of the Case Mix Groups (CMGs) for the IRF PPS.

AOTA supports IMPACT Act implementation and the broader goal of standardized data collection across PAC settings but will also comment in support of CMS-sponsored trainings and additional educational preparation opportunities to minimize disruption and confusion among IRF staff as much as possible. While CMS believes that the collection of the FIM^TM items and associated function modifiers is no longer necessary and that the continued collection of FIM^TM items, in addition to the IMPACT Act functional data reporting, places undue burden on IRFs, AOTA also understands that this will be a significant administrative and operational change for the IRF industry, likely requiring preparation, training, and transition time. Further, AOTA recognizes that there are concerns with the sensitivity of some items in Section GG.

In addition, AOTA is analyzing a provision in the proposed rule that would allow the rehabilitation physician to lead the interdisciplinary team meeting remotely without additional documentation requirements, to allow flexibility and convenience. AOTA is considering whether this flexibility should be extended to other interdisciplinary team members, including occupational therapists, and whether existing technology would allow for these types of remote interactions.

AOTA is currently developing comments that will be addressing the aforementioned proposed changes. AOTA encourages practitioners to review the CMS Factsheet on IRF PPS Proposed Rule and the Section GG Quality reporting Program Provider Training provided by CMS.

Email us before the June 26 CMS deadline at aota@regulatory.org, if you have comments or input regarding the IRF PPS proposed changes.