New IRF PAI Admit From & Discharge To – Considerations Abound
Now that the IRF PAI has changed, what are some considerations about ‘admit from’ and ‘D/C to’ that need to be discussed for your quality improvement processes? Did CMS miss the opportunity to assist you in gathering discharge ‘home’ information needed for longitudinal consideration and improvement?
For those of you deeply involved in the continuous quality improvement process within your IRF, you will note that some of the data fields used prior have now changed when considering ‘admit from’ and ‘discharge to’ location fields. Although during the comment period from the Proposed Rule to the Final Rule, I had made discussions on this area in particular, it just hit me recently that I perhaps left off some additional comments that would help in the improvement of longitudinal data specific to these fields. Let’s review the coding changes and the impact and considerations that need to be made regarding these fields.
First, a snapshot comparison PRE 2015 coding allowances: (note locations are the same for admit & d/c discussion purposes).
PRESENT 2015 IRF PAI CODING ALLOWED:
At first glance this may not generate much thought. However, specificity to the billing document codes should at least spark some communication to the discussions you must have internally while this data is being collected and potentially compared for trending and improvement opportunities. Are you aware of CMS’ definition of these specific location codes? If not, a particularly helpful MedLearn Matter SE0801 was revised in March 2014 that provides definition and clarification to these admit and discharge locations. The IRF PAI manual references these definitions for coding the IRF PAI in Section II.
A helpful crosswalk:
Be aware for longitudinal review that definitions are important in defining your patient population for comparison values. CMS is looking specifically at the cost of Post-Acute Care and how patients admitted to and discharged from IRF’s are utilizing resources associated with the Medicare Trust Fund. As we begin to review longitudinal costs of an entire episode of care, this data will become more meaningful. More specifically, CMS no longer allows the ‘Subacute Setting’ code which rehabilitation hospitals utilized when a patient continued therapy at a SNF. ‘Alternate Level of Care’ has no new definition found in the SE0801 location instructions. If you utilized this level previously, it may now be a ’99’ code.
We hope you find this information useful. Ultimately, IRF’s utilize discharge location as a matter of success. Discharge home with organized health care should be equivalent to the success of returning to the community or HOME, when outcomes monitoring. It appears to me that the opportunity was missed to designate ‘living with’ in codes 06 and 50. Perhaps we can ask for this inclusion in the 2016 Proposed Rule? Home or ‘community’ discharge and the resources required are crucial in our ability to define successful discharge. Next year we should be certain ‘home’ is labeled community and that we can gather appropriate resources no matter how that ‘home’ is labeled.
Lastly, the location code for discharge will now have applicable comparability to the the coded bill when comparing it to the IRF PAI. Be certain your staff utilize the appropriate definitions so that the bill is correct. If this area does not match the IRF PAI, it may be an area for an automated denial at the contractor level as it will be a more simple ‘audit’ in the future.