Tag: inpatient rehabilitation facilities

CMS Releases FY 2024 Final Rule for Inpatient Rehabilitation Facilities

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for federal fiscal year (FY) 2024.

Key provisions of the final rule include:

  • Rebasing the IRF market basket using data using FY 2021, instead of FY 2016 data.
  • Increasing the IRF PPS payment rate by 3.7% from $17,878 to $18,541 for IRFs that comply with the CMS IRF Quality Reporting Program (QRP) requirements. IRFs that fail to comply are subject to a two percentage point reduction.
  • Increasing the labor-related share from the current 72.9% to 74.1%.
  • Using the FY 2024 pre-floor, pre-reclassification inpatient PPS hospital wage index, with a 5% cap on any decrease to a provider’s wage index from its prior year wage index.
  • Decreasing the cost outlier threshold by 17% from the current $12,526 to $10,423, to achieve the 3% target for outlier payments as compared to aggregate IRF payments, which will increase the number of cases that qualify for outlier payments.
  • Updating the IRF QRP by:
    • Modifying the COVID-19 Vaccination Coverage among Healthcare Personnel measure.
    • Adopting one new measure: The Discharge Function Score measure.
    • Adopting the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure beginning with the FY 2026 IRF QRP.
    • Removing three existing measures:
      • The Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function measure (NQF #2631).
      • The IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients measure (NQF #2633).
      • The IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients measure (NQF #2634).
    • Modifying the excluded unit regulation to allow a hospital to open a new IRF unit and begin being paid under the IRF PPS at any time during the cost reporting period if the hospital meets certain requirements rather than the current limit that only allows for payment under the IRF PPS at the beginning of a cost reporting period.

The MHA will provide IRFs with a facility-specific impact analysis and additional details on the final rule in the near future.

Members with questions should contact Vickie Kunz at the MHA.

MHA Comments on Medicare Fee-for-Service Proposed Rules

Member News

The MHA recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed rule to update the Medicare fee-for-service (FFS) inpatient rehabilitation facility (IRF) prospective payment system (PPS) for fiscal year (FY) 2024. These comments were due to the CMS June 2.

The MHA has also drafted comments regarding the FY 2024 Medicare FFS proposed rule to update the inpatient psychiatric facility (IPF) and the proposed rule to update the skilled nursing facility (SNF) PPS.  Comments on these rules are due June 5.

The CMS is expected to release final rules to update the IRF, IPF and SNF PPS around Aug. 1, for the Oct. 1, 2023, effective date. The MHA will provide members with an updated Medicare FFS impact analysis following release of the final rules.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2024 Proposed Rule for Inpatient Rehabilitation Facilities

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRF) for federal fiscal year (FY) 2024. Key provisions of the proposal include:

  • Rebasing the IRF market basket using data from cost reports beginning in FY 2021, instead of FY 2016 data.
  • Increasing the IRF PPS payment rate by 3.3% from $17,878 to $18,471 for IRFs that comply with the CMS IRF Quality Reporting Program (QRP) requirements. IRFs that fail to comply are subject to a two percentage point reduction.
  • Increasing the labor-related share from the current 72.9% to 74.1%.
  • Using the FY 2024 pre-floor, pre-reclassification inpatient PPS hospital wage index, with a 5% cap on any decrease to a provider’s wage index from its prior year wage index.
  • Decreasing the cost outlier threshold by nearly 23% from the current $12,526 to $9,690, to achieve the 3% target for outlier payments as compared to aggregate IRF payments, which will increase the number of cases that qualify for outlier payments.
  • Updating the IRF QRP by:
    • Modifying the COVID-19 Vaccination Coverage among Healthcare Personnel measure.
    • Adopting one new measure: The Discharge Function Score measure.
    • Removal of three existing measures:
      • The Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function measure (NQF #2631).
      • The IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients measure (NQF #2633.
      • The IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients measure (NQF #2634).
    • Modifying the excluded unit regulation to allow a hospital to open a new IRF unit and begin being paid under the IRF PPS at any time during the cost reporting period if the hospital meets certain requirements rather than the current limit that only allows for payment under the IRF PPS at the beginning of a cost reporting period.

The MHA will provide IRFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members with IRF operations to review the proposed rule, provide comments to Vickie Kunz at the MHA by May 25 and submit comments to the CMS by June 2. The CMS is expected to release a final rule around Aug. 1, for an Oct. 1, 2023, effective date.

Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Aug. 15, 2022

Monday Report
MHA Monday Report

Primary Election Sets Field for November
MI Vote Matters

Michigan’s primary election was held Tuesday, Aug. 2, finalizing the November general election ballot. The 2022 midterm election is critical to Michigan’s healthcare future given the number of key elected positions up for election …

CMS Releases FY 2023 Final Rule to Update Hospital IPPS

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) hospital inpatient prospective payment system (IPPS) for fiscal year (FY) 2023. The rule will: Reduce disproportionate …

CMS Releases FY 2023 Inpatient Psychiatric Facility Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities for fiscal year (FY) 2023, which begins …

Final Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

The Centers for Medicare & Medicaid Services recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for fiscal year (FY) 2023, which begins …

CMS Releases FY 2023 Final Rule to Update Long-term Care Hospital PPS

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service long-term care hospital prospective payment system (PPS) for fiscal year (FY) 2023, which begins Oct. …

Survey Published for Opioid Use Disorder Contacts

In preparation for the state’s anticipated grant program to implement an Emergency Department Medication for Opioid Use Disorder (ED MOUD) program, the MHA is asking all members to fill out …

Hospitals Encouraged to Review Medicare Advantage Enrollment Plans

Medicare Advantage (MA) enrollment in Michigan totaled approximately 1.20 million in July, an increase of 15,000 beneficiaries since April. The July MA enrollment is spread across 47 MA plans that are currently operating in the …

Address Healthcare Employee Retention with Data ToolsSalary.com

It’s well known within the healthcare industry that issues of employee turnover, lack of applicants and salary compression were exacerbated in 2020 and 2021. Unfortunately, these trends have continued throughout …

Paul KeckleyThe Keckley Report

Solving Healthcare Workforce Shortages Requires Taking Self-care More Seriously

“The Labor Department reported that the U.S. added 528,000 jobs in July including 69,600 in healthcare. The unemployment rate fell to 3.5%, June job openings were down to 10.7 million from 11.3 million in May and government officials announced that the economy has now recouped the 22 million jobs lost in the pandemic.

But the more sobering news is that inflation has negated the workforce’ 5.1% wage gain in the last year and 1 in 5 workers is looking for employment elsewhere for higher pay and better benefits. And it’s even worse in the healthcare delivery workforce—the hospitals, long-term care facilities, clinics and ancillary service providers where 12 million work. During the COVID-19 pandemic, hospital employee turnover increased to 19.5%–five times higher than the general workforce. And today, 45% of physicians report burnout—double the rate pre-pandemic.”

Paul Keckley, August 8, 2022

News to Know

Members are reminded to review their preliminary wage and occupational mix data released May 23 by the Centers for Medicare and Medicaid Services and submit any requests for changes to their Medicare Administrative Contractor by Sept. 2 since no new requests for changes will be accepted after that date.

MHA in the News

MHA CEO Brian Peters

The MHA received media coverage on a variety of topics during the weeks of Aug. 1 and Aug. 8. Areas of focus included health insurance tax credits from the American Rescue Plan Act (ARPA), healthcare benefits in the Inflation Reduction Act, growing demand for healthcare careers and more.

Final Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a final 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 provisions of the rule include:

  • Requirement that the IRF-patient assessment instrument be completed on ALL patients, regardless of payor, beginning Oct. 1, 2024. This is delayed from the proposed Oct. 1, 2023 reporting date.
  • A 3.7% net increase to the IRF standard federal rate for providers in compliance with the CMS IRF quality reporting program, resulting in a rate of $17,878, up from the current $17,240. This increase is higher than the 2.7% proposed net increase due to comments received urging the CMS to more accurately reflect inflationary pressures experienced by IRFs and other providers.
  • Unchanged labor-related share with the CMS maintaining the current 72.9%.
  • Updated case mix group relative weights using updated FY 2021 claims and FY 2020 cost report data.
  • Permanent policy to limit annual wage index decreases to 5%.
  • A 32% increase in the outlier threshold amount from the current $9,491 to $12,526 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.
  • Codification of the existing teaching status adjustment policy for IRF closures and displaced medical residents.
  • Indication that the CMS will respond in a potential future rule to comments received regarding expansion of the IRF transfer payment policy to include patients discharged to home health.

The MHA continues to review details of the final rule and will provide IRFs with an updated impact analysis for Medicare FFS patients in the near future. Members with questions should contact Vickie Kunz at the MHA.