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Written by: Darlene D'Altorio-Jones (1959-2015) on Wednesday, June 15, 2011 Posted in: Inpatient Rehab

Recently I posted the individual changes for the highest volume  RIC and CMG that the proposed change could bring for your Medicare patients based on CMI value changes and the impact of moving to a new standard weight. I cautioned persons not to be elated by the news as the various facility-level adjustments held the larger picture when reviewing your specific admission patterns and historical volume prevalence by HIPPS for individual facilities. We asked facilities to review their own impact and to comment to CMS for final rule consideration. Time is running out to comment. There is now less than a week before 5:00 p.m., June 21st, 2011.

CMS published a prediction on the distributional change of the proposed rule as it relates to CMG relative weights for 388,591 cases.

The relative weight value can create a smoke and mirrors effect, if looked at independently.  It’s necessary to add the facility-level adjustment information on top of relative weight CMI at the CMG level to validate reliable expectation and individual change percent volumes.

The table above does not clarify the specificity of  ”Changed by less than 5%” as to whether it is up or down, making the overall effect appear harmless.  But beware, it’s important to know which direction your variance is headed.

Mediware has analyzed the data in a slightly different way. By applying HIPPS weighting for a sample size of facilities from very large to small discharge volumes, we calculated the effects of CMI and applied the individual published facility-level adjustments from the 2012 IRF PPS Proposed Rule file to each individual IRF. The tables included 1,146 facilities, which 1,123 had data for two consecutive years to work from.


Results are more telltale for the dollar difference you can expect when you apply facility-level adjustment factors.

“Change by less than 5%”, now only reflects 84% or 947 facilities.  Of that 84%,  34% (318) is negatively by less than 5% and 66% (629) is positively by less than 5%, given the applied facility-level adjustment calculations.

This contrasts the predicted 96.9% change by less than 5%, when only the CMI effects are evaluated. You can only predict reliably when you evaluate the conditions based on your own prevalence of HIPPS volumes and facility-level adjustments. The Mediware prevalence tool factored industry volume averages. Therefore if your patterns are similar,  it’s a beginning step to understanding the impact the rule will have on you.

You may never have exactly the same population as a previous year, but historically, you have patterns and placing those patterns against a calculator can help improve your predictions.

Have you speculated where your data suggests you may fall? Have you reviewed how this information will demand greater focus on the rigors of patient care management, including tight processes around functional improvement and dispelling barriers to discharge in a precise disciplined manner? Aligning staff very tightly to the discharge plan and honing the interdisciplinary goals with continuous attention toward solving discharge barrier issues suddenly became enormously important.

Do you have the reports and continuous quality monitors in place to see exactly where you stand in managing the patient on a daily basis? The plan of care was always important for the patient. The effectiveness of your process in meeting the interdisciplinary plan of care just became even more important for you to manage!

If you would like help in determining how your facility will be impacted by the 2012 proposed rule, please complete our online form.

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