Proposed Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2023, which begins Oct. 1, 2022. Key highlights of the proposal include a/an:

  • 2.7% increase to the IRF standard federal rate for providers in compliance with the CMS IRF quality reporting program (QRP), resulting in a proposed rate of $17,698, up from the current $17,240, for IRFs that comply with the IRFQRP.
  • Update to the case mix group relative weights using updated FY 2021 claims and the most recent cost report data.
  • Permanent policy to smooth the impact of year-to-year payment reductions related to decreases in the wage index. The CMS is proposing that an IRF’s wage index for FY 2023 and subsequent years would not be less than 95% of its prior year wage index.
  • Increase in the labor-related share from the current 72.9% to 73.2%, which will increase payments for IRFs with a wage index greater than 1.0.
  • 37% increase in the outlier threshold amount from the current $9,491 to $13,038 to maintain estimated outlier payments at 3% of total estimated aggregate IRF PPS payments. This will result in fewer cases being eligible for an outlier payment.
  • Modification to existing facility payment adjustments for teaching, low-income and rural IRFs.
  • Update to the existing policy affecting displaced medical residents.
  • Solicitation of comments on expanding the current IRF transfer policy to include discharges to home health as recommended by the Office of Inspector General.
  • Requirement that IRFs collect quality data on all patients, regardless of payer, beginning Oct. 1, 2023.
  • Request for information on some quality reporting-related topics:
    • Potential inclusion of an updated healthcare-associated infection measure in the IRFQRP. The National Healthcare Safety Network Healthcare-associated Clostridioides difficile Infection Outcome Measure would use data from electronic health records.
    • Feedback on strategies to improve measurement of disparities in healthcare outcomes. The CMS requests input on its framework to collect, stratify and report quality performance data across programs, as well as specific methods the agency could use with the IRFQRP.

The MHA will review details of the proposed rule and provide IRFs with an estimated impact analysis for Medicare FFS patients soon. The CMS is accepting comments until May 31. Members with questions should contact Vickie Kunz at the MHA.

Association Submits Comments on Medicare Post-acute Care Proposed Rules

The MHA recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rules to update the Medicare fee-for-service (FFS) prospective payment systems for fiscal year (FY) 2022 for several post-acute care settings including:

The CMS proposes to adopt a new measure — COVID-19 vaccination among healthcare personnel — in the quality reporting program for these facilities and would collect data beginning Oct. 1, 2021, with the quarterly vaccination rate publicly reported on the Care Compare website. The MHA opposes the adoption of this measure prior to full approval by the Food and Drug Administration.

The CMS also included a request for information in each proposed rule seeking ways to close the health equity gap. While the MHA supports efforts to close the health equity gap, the comment letters expressed concern about the increased administration burden associated with additional quality measures and standardized patient assessment data elements. The MHA urged the CMS to honor its “Patients Over Paperwork” initiative and streamline, align and focus on measures that matter most for patient care and outcomes.

The MHA is preparing comments on the FY 2022 proposed rules to update the inpatient and long-term acute care hospital prospective payment systems and encourages hospitals to contact Vickie Kunz at the MHA by June 18 with any issues identified. Members will have access to the draft comment letters for these rules prior to the June 28 due date and are encouraged to submit their own comments. Members may direct questions on any of the proposed rules to Vickie Kunz at the MHA.

News to Know – Week of March 1

Upcoming events and important healthcare news for the week of March 1:

  • As healthcare systems have battled COVID-19, those working closest to the virus have been significantly impacted by employee burnout. With greater patient loads, provider shortages and unforeseen complications, many have reported decreased positivity about their medical careers. MHA endorsed business partner Medical Solutions has developed a whitepaper that explores the challenges facing healthcare systems and explains how strong workplace cultures can lead to better recruitment, retention, and employee satisfaction during the pandemic and beyond. For more information on the MHA Endorsed Business Partner program, contact Peter Schonfeld at the MHA
  • The MHA is coordinating two free educational webinars hosted by DataGen to review the Medicare fee-for-service (FFS) quality-based programs. The webinar offered from 1 to 2 p.m. March 3 will review the Medicare value-based purchasing program, and the webinar available from 1 to 2 p.m. March 10 will review the readmissions and hospital-acquired conditions reduction programs. There is no cost for members to participate in the webinars, but registration is required. Members with questions should contact Vickie Kunz at the MHA.