Wednesday, 04 March 2015 17:24

Quality in IRFs Key Focus in Final Rule

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Original publication date of the article was September 2014

The Inpatient Rehabilitation Facility (IRF) Prospective Payment System Final Rule for the 2015 fiscal year was published on Aug. 6, 2014. The final published rule:

  • Updates the federal prospective payment rates for the 2015 fiscal year
  • Finalizes a policy to collect data on dollar amounts and modes of therapy provided in the IRF setting
  • Revises the list of diagnosis and impairment group codes that presumptively meet the “60-percent rule”
  • Updates the IRF-PAI to provide the IRF a way to indicate whether the prior treatment and severity requirements have been met for arthritis cases to presumptively meet the “60-percent rule”
  • Revises and updates quality measures and reporting requirementsDelays the effective date for the revisions to the list of diagnosis codes that are used to determine presumptive compliance under the 60-percent rule that were finalized during the 2014 fiscal year
  • Addresses the implementation of ICD-10-CM for IRFs

This article will address several key components of the final rule.

Updates to the Federal Prospective Payment Rates for FY 2015

Consistent with prior years, the regulations update the payment rates, including adjustments to the relative weights and average length-of-stay values for individual CMGs. The final rule also includes adjustments to the wage index and labor-related share amounts of calculating the individual IRF payment for a given CMG. The IRF standard payment conversion factor is increasing from $14,846 in 2014 to $15,198, a rise of 2.37 percent. For IRFs that failed to meet the quality reporting requirements, however, the standard payment conversion Factor will be $14,901 – a substantially smaller increase at only 0.37 percent.

Data Collection on Modes of Therapy

The final rule also finalizes the requirement of the documentation of minutes of therapy by therapy specialty and mode of therapy delivery. But furthermore, the final rule made several other important changes, including the addition of a definition for concurrent therapy, the removal of the requirement to record specific minutes beyond the second full week of therapy, and a decision not to establish limits on the amount of group therapy being provided.

The finalized definitions are:

  • Individual therapy is the provision of therapy services by one licensed or certified therapist (or licensed therapy assistant, under the appropriate direction of a licensed or certified therapist) to one patient at a time (this is sometimes referred to as ‘‘one-on-one’’ therapy.)
  • Co-treatment is the provision of therapy services by more than one licensed or certified therapist (or licensed therapy assistant, under the appropriate direction of a licensed therapist) from different therapy disciplines to one patient at the same time.
  • Concurrent therapy is one licensed or certified therapist treating two patients at the same time, with each patient performing different activities.
  • Group therapy is the provision of therapy services by one licensed or certified therapist (or licensed  therapy assistant, under the appropriate direction of a licensed or certified therapist) treating two to six patients at the same time, with each performing the same or similar activities.

The Centers for Medicare & Medicaid Services (CMS) recognized both the administrative burden required to collect therapy data as well as the average length of stay for IRF patients of 13 days in changing the requirement for data collection from the entire stay to the first two complete weeks of care. The revised requirements are reflected in the changes to the IRF-PAI document sections that have been added to collect therapy data.


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Last modified on Tuesday, 24 March 2015 16:50