Tag: quality reporting program

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.

Comments Due Aug. 16 on Medicare Home Health PPS Proposed Rule

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released the proposed rule to update the Medicare fee-for-service (FFS) home health (HH) prospective payment system (PPS) effective Jan. 1, 2023. Highlights of the proposal include:

  • A net 6.25% decrease in the national, 30-day standardized payment amount after the estimated 6.9 percentage point cut to achieve budget-neutrality for the Patient-Driven Groupings Model on a prospective basis. The proposed payment rate is $1,904.76, down from the current $2,031.64 for HHs that comply with HH quality reporting program (QRP) requirements.
  • An increase in the fixed-dollar loss ratio from the current 0.40 to 0.44.
  • A permanent 5% cap on wage index decreases to mitigate significant payment reductions from wage index changes.
  • Comment solicitation regarding the data collection on the use of remote services at the individual beneficiary level, which would allow the CMS to analyze the characteristics of the beneficiaries using remote services and potential for identifying social determinants of health that impact use of remote services.
  • Ending the suspension of data submission for non-Medicare/non-Medicaid patients. HH agencies would be required to submit all-payer OASIS data for purposes of the HH QRP beginning with the 2025 program year.
  • Changes to the Expanded HH value-based purchasing (VBP) model, including definitions for the baseline and model year, changing the baseline year from 2019 to 2022 for existing HH agencies and modifying the model year from 2019 to 2022 beginning in 2023.
  • Seeking feedback on development of health equity measures for the HH QRP and potential future application of health equity in the Expanded HH VBP model’s scoring and payment methodologies.

The MHA will provide members with an estimated impact analysis within the next few weeks and share draft comments prior to the Aug. 16 deadline. The MHA encourages members with HH operations to review the impact of the proposed rule on their operations and submit comments to the CMS. Members that have not received impact analyses in the past for affiliated, free-standing HH agencies are encouraged to provide the agency’s CMS certification number (also known as Medicare provider number), agency name, and federal information processing standards code to receive an estimated impact analysis in the future. Members are encouraged to forward this information and questions to Vickie Kunz at the MHA.