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IRF 2015 Final Rule Decisions – [CMS-1608-F]

Written by: Darlene D'Altorio-Jones (1959-2015) on Monday, August 4, 2014 Posted in: Inpatient Rehab

Prepare for 2015 IRF Final Rule Changes

Just when you may have believed there was no mercy in Medicare day-to-day decisions – the 2015 IRF Final Rule may prove otherwise. In reviewing the 66 comments that came into CMS for consideration and deliberations when finalizing this 2015 Rule, it is clear they felt too much had been planned for update in so little time.

The solution? Push a few more items back at least another year and slowly migrate to the full intentions delivered in the proposed items outlined earlier this spring.

Exactly what are those changes? Medicare reviewed them late last week in the CMS-1608 Final Rule.

Let’s begin by retrieving the IRF PAI that will be utilized 10/1/2014. They have also published the PAI that will be effective next year, 10/1/2015.

  • A policy to collect data on the amount and mode (that is, Individual, Concurrent, Group, and Co-Treatment) of therapy provided in the IRF setting according to therapy discipline during the first week (7 calendar day period) of the IRF stay; how many minutes of Individual, Concurrent, Group, and Co-Treatment Therapies the patient received, according to each therapy discipline, during the second week (7 calendar day period) of the IRF stay. Will now only collect this data by discipline for weeks 1 & 2 on the IRF PAI. Effective Oct. 2015 (2016 Rule).
  • Revises the list of diagnosis and impairment group codes that presumptively meet the “60 Percent Rule“ compliance criteria and provides a way for IRFs to indicate on the Inpatient Rehabilitation Facility-Patient Assessment Instrument (IRF PAI) form whether the prior treatment and severity requirements have been met for arthritis cases to presumptively meet the “60 Percent Rule” effective Oct. 2015 (2016 Rule).
  • This rule also delays the effective date for the revisions to the list of diagnosis codes that are used to determine presumptive compliance under the “60 Percent Rule” that were finalized in FY 2014 IRF PPS Final Rule and adopts the revisions to the list of diagnosis codes that are used to determine presumptive compliance under the “60 Percent Rule” that are finalized in this rule, effective Oct. 2015 (2016 Rule).
  •  Revises and updates quality measures and reporting requirements under the IRF quality reporting program (QRP).
  •  Updated quality measures and reporting requirements under the IRF QRP are applicable for IRF discharges occurring on or after Oct. 1, 2014. The two new IRF quality measures will require data submission, beginning with admissions and discharges occurring on or after Jan. 1, 2015:
    • (1) National Healthcare Safety Network (NHSN) Facility-Wide Inpatient Hospital-Onset Methicillin-Resistant Staphylococcus aureus (MRSA) Bacteremia Outcome Measure (NQF #1716)
    • (2) National Healthcare Safety Network (NHSN) Facility- Wide Inpatient Hospital-Onset Clostridium difficile Infection (CDI)
  •  ICD-10-CM becomes the required medical data code set for use on Medicare claims and IRF PAI submissions when finalized through government law.

Data files for FY 2015 have all been updated from Federal Register 79; 26308 where the IRF Final Rule will be published. These files include the newest rate setting files that have been tweaked as final for CMI payment schedules and length of stay tables. A wage index file and presumpive compliance under ICD-9 and 10 files are all found at that link.

Of note is that the IRF PAI signature page is the designation of this statement:“that I collected or coordinated collection of this information on the dates specified.”

This statement seems to signal that it is not the intention that every person assessing the patient would need to sign but only those that dedicate the information to the IRF PAI through the course of the stay and preparing the final copy for upload to CMS.

Items that were stated ‘mandatory’ and ‘voluntary’ for quality pressure ulcer measurement will remain as such.

Overall, there are fairly light changes. Familiarlize yourself with the documents and links provided and stay tuned for a Final Rule inservice outlining these items and impacts!