Final Revision Of 2021 Prospective Payment System For Inpatient Rehabilitation Facility By CMS

Inpatient Rehabilitation Facility

Payment System For Inpatient Rehabilitation

For the fiscal year 2021, CMS has announced to update the IRF PPS payment rates by 2.4 percent. This percentage represents a 2.4 percent IRF market basket. CMS has announced an update PPS for an inpatient rehabilitation facility. Its purpose is to reduce point multifactor productivity adjustment by 0.0 percentage.

Updates To IRF Rules:

The Centers Of Medicare and Medicaid Services (CMS) has issued the final rule about PPS (Prospective Payment System). They have announced that they are going to update Medicare payment policies and rates for the “Inpatient Rehabilitation Facility” for the fiscal year of 2021.

CMS has published the final rule with legal requirements to update Medicare payment policies for IRFs on an annual basis. This rule consists of the following regulatory changes;

  1. They have announced permanent changes in the rules.
  2. They have eliminated the requirements for physicians to conduct a post-admission visit. Because healthcare providers can collect sufficient information in the pre-admission screening documentation.

They have introduced this flexibility during the public health emergency of COVID-19. Also, they have decided to extend this flexibility beyond the expiration of the PHE.

Especially, CMS has not finalized any changes to the IRF Quality Reporting Program (QRP) for 2021.

Requirements For Medicare Inpatient Rehabilitation Facility Coverage:

If providers want to justify an IRF claim with valid reasons. So that Medicare considers it medically important under the section of 1862(a)(1) in the Social Security Act.

Right at the time of the patient’s admission to the IRF. Patients should meet the criteria of reasonable expectations to meet the requirements of the IRF coverage.

In the Fiscal Year 2021, CMS has finalized certain changes in the IRS PPS final rule. These changes were made to create standard codes for existing documentation instructions and guidance.

Ultimately, it will improve the clarity of the information mentioned in the documents and reduce administrative burden. Hence, it will introduce feasibility for both_ IRF providers and Medicare Administrative Contractors (MACs).

Evaluation For Post-Admission Physician:

Currently, IRFs are required to proceed with a post-admission physician evaluation within the first 24 hours of the patient’s admission. Although, it is not applicable during the public health emergency of COVID-19.

In October 2020, CMS has already finalized the permanent elimination of the post-admission physician evaluation. Because they have to include the same information about the pre-admission screening of the patient and the patient’s healthcare plan.

According to the instructions provided by the patient’s physician or other treating clinicians, IRFs still have flexibility during patient care. If it is essential due to the current medical condition of the patients. Then IRFs are allowed to conduct patient visits within the first 24 hours of an IRF admission.

Improved Flexibility for Physicians:

In order to make sure that medical providers are working according to the patient’s care plan. Currently, it is required that physicians should conduct three visits to each patient per week.

Other qualified healthcare providers may have to perform additional visits to their patients. The intent of these visits is solely based on the clinical necessity of the patient’s medical condition.

Non-physician practitioners (NPPS) are the most important components of interdisciplinary patient care treatments. More often, they support physicians to conduct healthcare services during their visits to patients.

On average, patients have to stay in IRF for intensive rehabilitation therapy at least for 13 calendar days. However, CMS has finalized that an NPP may perform one of the three required visits instead of the physician.

They can proceed with this treatment in the second and later weeks of the patient’s care plan. In recognition of the interdisciplinary role that NPPs are currently providing to the patients in the IRF.

But IRFs have to comply with the NPP’s state of the scope of their practice. Currently, CMS has provided flexibility to physicians to see the patient three or more times a week. CMS is going to pursue the requirements that a physician should review and concurs with the preadmission screening for the following entities;

  • IRF admission.
  • Develop a well-organized patient care plan.
  • Leads the weekly interdisciplinary team conferences.

These conferences will include nurses, social workers, case managers, and treating therapists who proceed with the patient’s care plan.

Updates To IRF Payment Rates:

Most importantly, CMS has announced an additional 0.4 percent increase to aggregate payments due to updating the outlier threshold. Ultimately, it will maintain estimated outlier payments at 3.0 percent of total payments. As a result, it will cause an overall update of 2.8 percent (or $260 million). It will be applicable for the payments that are relative to FY 2021.

Also, they have announced that they are implying the recent Office of Management and Budget (OMB) statistical area delineations. Moreover, they are also applying a 5 percent cap on wage index decreases from FY 2020 to FY 2021.

Healthcare providers are consistently struggling with social-economic issues due to COVID-19. They need more equipment and resources to manage increased patient flow. CMS has introduced increased flexibility to IRF so they can manage their patient’s care plans more conveniently.

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