I recently provided an in-service for about 20 different IRF facilities in Ohio where I shared train-the-trainer information and links to help prepare rehabilitation facilities for the new Quality Monitoring for fiscal year 2013. The information I presented was from what I learned when I attended the Inpatient Rehabilitation Facility PAI Train-the-Trainer Conference provided by CMS.
After returning home and alerting their quality department, one participant from the in-service with a small unit certified as an inpatient rehabilitation facility was told by their quality department they did not have to register their unit any differently than their acute hospital. I suppose they already share their rehab unit CAUTI data. The quality staff informed the in-service participant that unless they were a “free standing” unit, they did not have to register differently or report differently.
Specifically if you are a unit within a larger hospital system, I implore you now to talk and discuss your unit registration and expectations with your quality representative. The National Health Safety Network (NHSN) has an informative 14-page handout called,”Updates to NHSN for IRF Locations within Acute Care & Critical Access Facilities” that I recommend you read.
If the CMS Certification number does not have an “R” or “T” in the third position, but instead has the last four digits between 3025-3099, the IRF must be enrolled as a separate facility and not as a location within the acute care facility. This does not mean that units do not have to reallocate these specific beds to the certified IRF unit.
Be proactive. NHSN says, “The updated functionality within NHSN will allow users to designate specific rehab locations within the facility as separately licensed CMS units. In addition, users will be able to enter the rehab specific CCN, thus allowing the data to be appropriately sent to CMS to satisfy IRF PPS reporting requirements.” If you do not want to experience the 2.0% reduction to your annual payment update formula, follow-up and make sure your quality department is well aware that reclassifying your beds is key to getting the correct information to CMS. Stand firm! Educate and protect your ability to receive appropriate payments. Specifically, when in fact, you are submitting data on the beds designated for IRF PPS rate payment.