Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) Final Rule for 2020

The Centers for Medicare and Medicaid Services (CMS) issued the final FY 2020 IRF PPS rule outlining changes to reimbursement and quality reporting for inpatient rehabilitation facilities (IRFs) on August 8, 2019. CMS finalized updates to the IRF PPS payment rates and projects that IRF payments will increase by 2.5% or $210 million. Below is a summary of some of the key changes that have implications for occupational therapy practitioners in FY 2020, followed by more information on each. CMS:

• Now allows IRFs to determine whether physicians qualify as rehabilitation physicians.
• Is adding two new measures to the IRF Quality Reporting Program.
• Is excluding baseline nursing facility residents from the Discharge to Community—PAC IRF QRP. AOTA advocated for this exclusion.
• Adopted several standardized patient assessment data elements (SPADEs) for the IRF-PAI to improve communication and continuity of care.
• Is not implementing the weighted motor scale. AOTA advocated for this.

Definition of Rehabilitation Physician

CMS has finalized its proposal allowing IRFs to determine whether physicians are qualified as rehabilitation physicians. AOTA had encouraged CMS to not finalize the proposed amendment, instead recommending that CMS convene stakeholders to develop a definition of rehabilitation physician that would establish a level of competency and privileging/credentialing to ensure that IRF patients are being served by appropriately trained and experienced rehabilitation physicians.

However, CMS stated that although the existing regulation requires a rehabilitation physician to be a licensed physician with specialized training and experience in inpatient rehabilitation, it was necessary to clarify that the IRFs determine that any given physician qualifies as a rehabilitation physician. CMS indicated that it will continue to assess whether future refinements to the definition are needed.

IRF Quality Reporting Program

CMS has finalized its proposal to add two new measures to the IRF Quality Reporting Program. These two new measures (Transfer of Health Information to the Provider—Post-Acute Care (PAC) and Transfer of Health Information to the Patient—Post-Acute Care (PAC)) are intended to promote effective communication and coordination of care and assess whether the IRF has provided a reconciled medication list upon transfer or discharge. CMS will begin collecting data for discharges beginning October 1, 2020.

Additionally, CMS updated the specifications for the Discharge to Community—PAC IRF QRP measure to exclude baseline nursing facility (NF) residents from the measure. AOTA advocated for this exclusion in the past and continues to support it. CMS believes the exclusion will result in the measure more accurately portraying quality of care provided by IRFs, while controlling for factors outside of IRF control.

Finally, CMS adopted a number of standardized patient assessment data elements (SPADEs). These SPADEs assess key domain areas including functional status, cognitive function and mental status, pain interference, and social determinants of health (SDOH). CMS stated that adding these SPADEs to the IRF-PAI should improve communication and continuity of care among providers as patients transition between settings.

Weighted Motor Score

Initially, CMS had proposed replacing the unweighted motor score with a weighted motor score to assign patients to case-mix groups starting October 1, 2019. AOTA and other stakeholders urged CMS to delay implementing the weighted motor score in order to further analyze and refine the weighting methodology. In light of the overwhelming support from comments to continue to use an unweighted motor score until more analysis can be performed, CMS finalized the use of an unweighted motor score, meaning each of the items used in the score has an equal weight of 1. The unweighted motor score will be used to assign patients to case-mix groups beginning with FY 2020. Also of note: CMS is finalizing the removal of one item (GG0170A1 Roll left to right) from the motor score beginning October 1, 2019.

Occupational therapy practitioners are encourage to review the fact sheet for the IRF final rule for more information. Email questions to regulatory@aota.org.