By Kristen O’Brien, JD
Vice President, McDermott+ Consulting
Last week, the Centers for Medicare and Medicaid Services (CMS) released the FY 2022 proposed rule for inpatient rehabilitation facilities (IRFs), which updates payment rates, make adjustments to the case mix group (CMG) weights, and includes proposals for the IRF Quality Reporting Program (QRP). Compared to past rules, this proposal was fairly light on significant new policy developments but does include a number of important changes for rehabilitation medicine providers. AMRPA provided a detailed summary of all the provisions in the rule via its On the Record Special Edition update, but this blog post notes some of the important proposals in the regulation.
1.8% Proposed Payment Update
Although CMS proposes a 1.8% increase, this is lower than FY 2021 rule, where CMS finalized a 2.4% update. The agency does, however, note that if more recent data becomes available between now and publication of the final rule, this could change the final rates. CMS is also requesting feedback on whether FY 2019 claims data or FY 2020 claims data should be utilized to update payment rates due to the COVID-19 public health emergency.
Proposed New Measure: COVID-19 Vaccinations Among Healthcare Personnel
In efforts to address COVID-19 and assess whether organizations are taking steps to limit the spread of COVID-19 among their Healthcare Personnel, CMS has proposed a measure to require IRFs to report COVID-19 personnel vaccinations. IRFs would submit data for a minimum of one week per month beginning with the FY 2023 IRF QRP. Similar measures were included in other proposed payment rules, including those for skilled nursing facilities.
An important theme in the rule reflects the Biden administration’s focus on health equity. In a request for information (RFI) included in the rule, CMS is signaling future increased requirements for data collection related to health equity and other social and behavioral determinants of health including frailty, opioid use and frequency, patient reported outcomes, shared decision-making process, appropriate pain assessment and pain management processes and health equity.
Currently, CMS has adopted several standardized patient assessment data elements (SPADEs) that include several social determinants of health (SDOH) that were finalized in the FY 2020 IRF PPS final rule. In this proposed rule, CMS is also seeking comment on the possibility of expanding measure development and the collection of other SPADEs that address gaps in health equity in the IRF QRP.
AMRPA will be working with our relevant committees to draft comments on the rule, which are due June 7.
Review the proposed rule here: Federal Register: Public Inspection: Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program
Review the CMS fact sheet here: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2022-inpatient-rehabilitation-facility-irf-prospective-payment-system-pps-proposed