Each year CMS proposes the annual fate of how we will manage our business in the upcoming fiscal year. This year is no different. The proposed 2012 regulations were released for comment on April 29, 2011 and can be found at the CMS website.
At a high level;
- Quality indicators that were once voluntary will be required for reporting to the Secretary of Health and Human Services by 2014 to avoid a two percent reduction in the annual increase factor for failure to report data. Chosen so far are pressure ulcer monitoring and catheter associated urinary track infections.
- There are updated CMI weights and LOS CMG tables.
- Revision to payment adjustment factors (Table 10 of the rule. Page 24245).
- Consolidation, clarification and revision of policies regarding IRF hospital or units to eliminate confusion.
- Amended regulatory provisions regarding new facilities and changes in bed size or square footage.
What does this mean for your IRF after October 1, 2011? Now is the time to review, prepare and at the very least, analyze your specific admissions practice to validate strategic changes to ensure patient access and continued strength as a provider.
If upon analysis you believe portions of the rule requires comment, specifically in the payment adjustments and the rationale proposed for those changes, be sure to offer those comments on your own or through organizations that support the practices of rehabilitation. Comments must be received by CMS no later than June 21, 2011 – noting CMS-1349-P. See rule for further details.
Snapshot comparison of 2011 to 2012 – Numbers following the specific rehabilitation impairment category (RIC) reflect the number of CMGs possible based on tiers A, B, C and D. Also note that projections on payment are based solely on case mix related to the standard rate before facility adjusters are applied and compared to 2011 rule values.
How CMS feels these changes will affect the distribution on cases paid.