Earlier this month, clinical consultant Virginia Littlepage presented a webinar packed with all the information you need about the IRF PPS 2018 final rule and what changes to expect for FY19. We compiled the most commons questions and their answers below. If you missed it, you can watch the recording here.
Did CMS give any reason why it did not finalize the data collection elements that were proposed?
There are five categories in the IMPACT Act that require standardized patient assessment data elements.
The first two are functional status and medical conditions and comorbidities. Data is already being collected in both categories, so these are already covered.
The three remaining categories are cognitive functioning and mental status (CAM); special services, treatments, and interventions; and impairments.
In the proposed rule, the additions would have met the needs of those three categories; however, based on the comments CMS received, it seemed clear that introducing these elements now would create an additional reporting burden on IRFs.
CMS now intends to conduct a national field test to allow stakeholders to give more feedback. After that, CMS is going to consider how to maximize the time IRFs have to prepare for having to report these data. The goal is to give more lead time for preparation rather than attempt to implement all those changes at the same time, as we had to last year
Are these elements going to be added in next year?
CMS plans to present new proposals for the three categories no later than FY 2020. The proposed rule is expected to be published sometime in May 2019 with an implementation date of Oct. 2019.
Have the new ICS-10 codes been delivered?
New ICD-10 codes have been published. Check with your software vendor to determine if your system has been updated with the new codes. If your software hasn’t been updated, your vendor should be able to provide a date when the new codes will be added.