Mediware Rehabilitation Blog

Patient Oversight vs. Site-Neutral Payment; Patient Requirements Should be First

Have regulatory changes that steered rehabilitation patients of lesser CMG values away from IRF fueled the growth of other post acute care venues? Have the shifts that occurred made good financial sense to CMS? Have acute care practices and lengths of stay changed over the past 20 years necessitating more robust post-acute care readiness? The answer to these questions hold the key to what lawmakers need to consider when it comes to recommending site-neutral payment in IRFs and SNFs, even for limited orthopedic conditions.

Let's review these concepts in Blog 3 of the series on site-neutral payment and why now more than ever a specialized level of rehabilitation care (IRF) should not be considered comparable in services or payment to a SNF level of care. If patients are screened and directed appropriately based on their real medical and functional needs, there would be no need to concoct 'site- neutral' relationships.

 

May IRFs Use All IRF PPS CMGs Without Reprisal?

Resources federally mandated to admit and care for patients at a rehabilitation ‘burden of care’ facility and payment based on the IRF PAI driven assessment has historically created acuity payments in higher CMGs. This reality is what fueled the experience noted in the June MedPAC study that, ‘on average’, payments to IRFs, when compared to SNFs, can be higher. In this second discussion on site-neutral payment, and why it should not be considered at this time in Congress, let's review the present possibilities of payments and why we should access those first before paying a site-neutral payment that is not always commensurate with the real burden of care for a patient treated in an IRF.  

Let's also say that when a patient admitted to an IRF has a lower acuity, the payment available and paid will follow that experience too! Yes, even in an IRF.

Can Site Neutral Payment Discussions be Stopped?

Site-neutral payment has been garnering a lot of attention lately, with various government agencies discussing equal pay for equal treatment, and then using actual data files within CMS to make arguments for equal pay. Meeting the Three AIMS of CMS to obtain better value for dollars paid in healthcare is important; however, these studies attempt to neutralize real differences that, in hindsight, cannot be made vanilla in the ways they have applied rationale to make comparisons.  

To defend medical necessity, IRF resources, outcomes and patient types have moved to higher acuity. Comparing real costs may show that it costs more, on average, to treat patients in an IRF; however, on average, IRFs do not have the same population of patients they ‘signed up for’ when IRF PPS payment began in 2002. Unless consideration is given to what has caused this shift, discussions on site neutral payment needs to be stopped in its tracks (if it is not too late already) and we need to educate lawmakers about how they got IRFs to realize the differences they are seeing when real patient data is compared.

What to Expect in 2015

This year, the post-acute care provider will see significant changes leading to how patient care will be paid and managed. Payment reform continues to focus achieving the 'Triple Aim' objectives of Quality, Cost and Value in health care for the nation’s population. PAC providers will begin preparing to operate in a delivery system where payment is bundled with other providers, requiring coordination and communication to achieve expected outcomes.

IRF PPS Training Event Scheduled 2015

If preparation is the name of your game then you don't not want to miss the newest posted MedLearn Matter Training event for IRF PPS. If you recall, last year they had already defined several areas that would be published and utilized in the 2016 fiscal year beginning October 1, 2015. If you want to sign-up for that education, take the time to do it ASAP as the training date is January 15.

LOS Revisited

Rehabilitation hospitals have routinely valued length of stay (LOS) as a key metric for assessing hospital performance both clinically and financially. Tracking, reporting and comparing LOS has occupied the past times for many administrators seeking the strategic advantage to improve performance.

NCCI Modifier Madness - No Need for that!

Modifier alerts occur when CMS attempts to further differentiate the services provided and whether those services are payable as distinct and separately. Way back in 1996, NCCI edits began and have evolved to mutually exclusive and component codes that are generally considered non-payable on the same date of service. This is true unless you append that line on your bill with the 59 MODIFIER that specifically permits the 'unbundled' payment. How often have you used or needed to use the modifier in your practice? Some facilities, by the nature of what they do, will systematically trigger the need more often. Let's discuss because the new 'X' modifiers are causing some 'ruckus'. There is more than a month to plan and educate... now let's discuss if you are one of those practices!

 

Preparing for IMPACT

It has been a month since the President signed into law the Improving Medicare Post-Acute Care Transformation Act. This Act focuses on improving the contribution of post-acute care to our nation’s objectives of improving the health of the population, enhancing the experience and outcomes of the patient, and reducing per capita cost of care for the benefit of communities.

Population Healthcare Management (PHM) - The Foundation of Future Leadership

Population Healthcare Management (PHM) is a concept in healthcare that will not soon disappear. And, although as a concept the definitions of PHM is still being defined, I think more than ever the need for communities at large to engage in appropriate and well dispersed population health concerns are reaching a peak of imperative understanding. It takes no less than the present 'ebola crisis' to help reiterate how truly connected we are as individuals sharing common spaces, air and yes - health!

Inpatient Physician Accountability Reaches into the Part B Payment Pocket

There have been long awaited discussions of how to keep the part B reimbursed physician in alignment with the acute care responsibilities of oversight and management of the patient; we have heard that at some point denied inpatient stays could result in denied part B payment as well. Has the time come? Keeping the physician's 'skin in the game' just got a little more serious as it relates to following conditions of participation, medical necessity documentation and general adherence to level of care physician oversight.

Facility Location and IRF PAI Patient Vaccinations Must Be Understood

It is imperative that the person answering and collecting data on your IRF PAI in regards to Patient Flu Vaccination FULLY understand that the IRF is a distinct and separate 'facility' from your acute care units when you have an IRF within an ACUTE CARE hospital system. The IRF PAI instructions may not fully spell this out but CMS has guided us in several other ways to be certain this particular question is answered appropriately. Follow these instructions....

The IRF’s Future Depends Upon the Ability to Deliver Unique Rehab Value

The Rehab Model of Care (problem oriented, goal directed, coordinated, team delivered) is being replicated across all healthcare. These models target improved coordination of care, fewer errors, lower costs and improved patient outcomes. The demand for cost-effective and preventive care that also reduces overuse and misuse has providers turning to the structure and processes of the team delivered collaboration models. While functional impairment and the restoration of activity-participation remains the purview of IRFs, other healthcare organizations adopt this model and venture to provide a therapeutic approach to functional restoration.