Tag: IRF

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 Skilled Nursing Facility Proposed Rule

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities (SNF) for fiscal year (FY) 2024, beginning Oct. 1, 2023. The CMS did not propose new minimum staffing requirements for SNFs in this rule but restated the agency’s intention to propose such requirements in separate rulemaking this spring. Key provisions of the proposal include:

  • Continuation of the negative 2.3% parity adjustment to the Patient Driven Payment Model (PDPM) case mix indices following implementation of the PDPM to maintain budget neutrality with the prior RUG-IV case-mix system. The CMS finalized a two-year phase-in of the proposed 4.6% negative adjustment for FY 2023 and 2024 despite opposition from the MHA, the American Hospital Association and others.
  • A 3.7% net increase to the SNF federal per diem base rate for providers that comply with the CMS IPF quality reporting program (QRP) requirements. Facilities should note that the 3.7% net increase will be offset by the negative 2.3% parity adjustment described above.
  • A slight increase in the labor-related share from the current 70.8% to 71%.
  • Changes to the SNF QRP including:
    • Adopting one new quality measure: The Discharge Function Score (DC Function).
    • Modifying the COVID-19 Vaccination Coverage Among Health Care Personnel measure.
    • Removing three measures:
      • Application of Percent of Long-Term Care Hospitals Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function.
      • The Application of the IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients.
      • The Application of the IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients.
    • Adopting four new measures for the SNF Value-based Purchasing (VBP) program:
      • Nursing Staff Turnover Measure.
      • Discharge Function Score Measure.
      • Long Stay Hospitalization Measure per 100 residents.
      • Percent of Residents Experiencing One or More Falls with Major Injury (Long-Stay).
    • Replacing the 30-Day All Cause Readmission Measure with Within Stay Potentially Preventable Readmissions Measure.
    • Adoption of Health Equity Adjustment.

The MHA will provide SNFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members with SNF 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 5. 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.

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.