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IRF 2015 Final Rule – Let the New Rule Begin

Written by: Darlene D'Altorio-Jones (1959-2015) on Wednesday, October 1, 2014 Posted in: Inpatient Rehab

As promised, CMS released the 2015 IRF PAI manual. In the link on the CMS website, it was released in 20 different ‘chapters’ for the 13 sections. Please be aware that although the CMS data flow area is Section 12 there is not a header for that on the page so it appears to skip from Section 11 to Section 13. In addition, at the link provided by CMS, they name files up through 21 but not all are sections. We hope that by pulling these all into one file this will be helpful as a file you can save, print and educate your staff to the new version.

What else is new as of today (10/1/14)?

  • The IRF PAI is the 8 page version with updated areas and field selections;
  • Section IV is the Quality Indicator section but ONLY covers items that are IRF PAI specific;
  • 2015 NHSN Quality Reporting criteria and dates for reporting. Be aware that these are NHSN items and that two of those items will NOT be collected and reported for IRF’s until Jan 1, 2015;
  • Fiscal YEAR 2015 DATA FILES are available for your update; Please note that the latest version includes EFFECTIVE DATES on the file names as not all are effective for this fiscal year and become effective Oct. 1, 2015!

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Lastly, be aware that the signature page does not require every person that has assessed the patient, but specifically ANY person that has added, updated or contributed specifically to the IRF PAI that will be uploaded to the government. That page will not be transmitted to CMS but is expected to be kept in the official Medical Record so that the responsible persons, date and time of changes are tracked just like all other contributions to the medical record. This file requires actual signatures and will not be tracked via IRVEN software or other vendor data fields for transmission.

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If you missed the 2015 Final Rule webinar and all the helpful links and information provided in that presentation, you may now access the 2015 Final Rule Webinar presentation.

There is plenty of time to file the new IRF PAI; there has been no change in the late transmission time lines which gives you more than three weeks to settle in, take a deep breath and be sure you have all the information required. Many have been completing the new IRF PAI data for the last couple of weeks given the average LOS of about 14 days on rehab and anticipating discharges after this date.

Change is inevitable in the daily grind of healthcare. CMS has proven that IRF’s are to expect continuous changes going forward. Utilize these links and we’ll discuss more changes to be expected with the filing of the IMPACT ACT just recently. Stay tuned!