On Friday, just in time to ruin a beautiful spring weekend, CMS released the FY 2019 Inpatient Rehabilitation and the Inpatient Psychiatric Hospital Prospective Payment System annual reimbursement updates.
These are relatively quiet areas of policy these days but, at least as far as IRFs go, did not escape FY 2019 rulemaking without some influence of the Trump administration.
Inpatient Rehabilitation Facilities.
The annual payment update is without surprises or Congressional meddling. The base discharge rate will increase 1.15 percent.
IRF High-cost Outlier Payments. CMS is increasing the outlier threshold from $8,679 in FY 2018 to $10,509 in FY 2019 to maintain the estimated outlier payments at 3 percent of total aggregate IRF payments. The estimated FY 2019 outlier payments are now estimated at 3.4 percent, hence the rather large increase the in the threshold for FY 2019
Changes to Documentation Requirements. In last year’s rulemaking, CMS requested information on how to improve the Medicare program, reduce administrative burden and improve the quality of care. In response to that RFI, CMS has made a couple of proposals designed to reduce the documentation burden on IRFs.
Their proposals are:
- Changes to Physician Supervision Requirement – Would permit the post-admission physician’s evaluation to count as one of the three face to face visits in the first week after admission
- Changes to Interdisciplinary Team Meeting Requirement – Would expressly provide that the rehabilitation physician may lead the interdisciplinary meeting remotely without any additional documentation
- Changes to Admission Order Documentation Requirement – Would remove admission order requirement as CMS feels it is met through compliance with other Medicare regulations
Relief from documentation requirements is important because so much of the Medicare improper payment rate – which in turn gives rise to the Medicare Administrative Contractors’ prepayment review and Recovery Audit Contractors’ post-payment review – is the result of incomplete documentation.
However, in the case of IRFs, documentation is not as much of an issue. Most of the IRF improper payment rate is due to MAC and RAC findings that treatment was medically unnecessary, meaning the patient’s condition did not justify admission to an IRF.
But, it is something, I suppose.
Request for Information on other issues. For the second year, CMS is requesting information on improvements to the program. Specifically, they are asking:
- Whether the rehabilitation physician should have the flexibility to determine that some of the IRF visits can be appropriately conducted remotely
- Whether non-physician practitioners should be permitted to meet face to face requirements and other assessments
Finally, and consist with other FY 2019 payment rules, CMS is asking for ideas on enhancing interoperability. CMS is considering incorporating into Medicare Conditions of Participation requirements that providers release medical record electronically to patients and other providers in a form that is usable.
Inpatient Psychiatric Facilities
IPF policy is a virtual wasteland of new ideas, which is ironic given the scourge of the opioid epidemic. The rule does include some administrative burden reduction in the form of changes to reported quality measures and the like. Otherwise, it is mostly about the payment update.
The outlier threshold is being increased to $12,935 to maintain outlier payments at 2 percent of all IPF reimbursement.
Call with questions. We will answer if we aren’t outside trying to make up for a beautiful weekend spent reading the Federal Register.
Emily Evans
Managing Director
Health Policy
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