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Quality Proposals from IRF, IPF and Hospice FY 2020 Payment Rules

April 23, 2019

McDermott+Consulting

The Centers for Medicare and Medicaid Services (CMS) has begun the annual update of Medicare payment policies. FY 2020 proposed regulations for Inpatient Rehabilitation Facilities (IRF), Inpatient Psychiatric Facilities (IPF) and Hospice were recently released by the agency. While the bulk of the rules are focused on payment policies, CMS also uses these rules to propose updates to the various quality programs.

FY 2020 IRF Proposed Rule

On April 17 CMS issued a proposed rule for the inpatient rehabilitation facility (IRF) prospective payment system for fiscal year (FY) 2020. CMS proposes to increase IRF payments by 2.3 percent ($195 million) in FY 2020, and rebase and revise the IRF market basket using more recent data.

The IRF Quality Reporting Program (QRP) is authorized by section 1886(j)(7) of the IMPACT Act and was implemented in FY 2012 IRF PPS final rule. The IRF QRP collects and publishes data on quality measures and collects standardized patient assessment data. IRFs that do not satisfy the requirements of the IRF QRP receive a two percent reduction to their annual increase factor for discharges.

  • CMS is proposing to adopt two new quality measures.  The two proposed measures are: 1) Transfer of Health Information to the Provider—Post-Acute Care (PAC) Measure; and 2) Transfer of Health Information to the Patient—PAC Measure.
  • CMS is also proposing to adopt a number of standardized patient assessment data elements to the IRF-Patient Assessment Instrument (PAI).
  • CMS is also proposing to update the specifications for the Discharge to Community Post-Acute Care IRF QRP measure to exclude baseline nursing home residents and to no longer publish a list of compliant IRFs on the IRF QRP website. Also in response to public input, CMS is proposing to collect standardized patient assessment data and other data required to calculate quality measures using the IRF PAI on all patients, regardless of the patient’s payer.

CMS will accept comments on the proposed rule until June 17, 2019. The fact sheet on the 2020 IRF Proposed Rule is available here. The 2020 IRF Proposed Rule can be downloaded here.

FY 2020 IPF Proposed Rule

On April 18 CMS issued a proposed rule to update the payment rates for IPFs for FY 2020. The agency proposes a net payment increase of 1.7 percent, or $75 million, compared to FY 2019.

Eligible IPFs that do not take part in the IPF Quality Reporting Program, or do not meet all of the reporting requirements, will have a 2.0 percent reduction of their annual update to their standard federal rate for that year. For FY 2020, CMS is proposing to adopt one new claims-based measure beginning with the FY 2021 payment determination and subsequent years.  This measure, Medication Continuation Following Inpatient Psychiatric Discharge (National Quality Forum #3205), assesses whether patients admitted to IPFs with diagnoses of Major Depressive Disorder, schizophrenia or bipolar disorder filled at least one evidence-based medication within two days prior to discharge or during the 30-day post-discharge period.

CMS will accept comments on the proposed rule until June 17, 2019. The fact sheet on the 2020 IPF Proposed Rule is available here. The 2020 IPF Proposed Rule can be downloaded from here.

FY 2020 Hospice Update

On April 19 CMS issued a proposed rule to update the payment rates for hospices for FY 2020. CMS proposes a net increase to payments of $540 million, compared to FY 2019. This includes a 3.2 percent market-basket update, offset by a statutorily-required reduction of 0.5 percent for productivity.

The Hospice Quality Reporting Program (QRP) was established in FY 2012.  There are 10 measures currently adopted for the Hospice QRP. In the FY 2020 proposed rule, CMS proposes to continue data collection on the measure “Hospice Visits over the Last 7 Days,” one of the companion measures in the “Hospice Visits When Death Is Imminent” measure pair, but proposes not to publicly report this measure at this time. CMS also proposes a change to an exemption from the Consumer Assessment of Healthcare Providers and Systems Hospice Survey participation requirements.

CMS will accept comments on the proposed rule until June 18, 2019. The fact sheet on the FY 2020 Hospice Proposed Rule is available here. The 2020 Hospice Proposed Rule can be downloaded from here.

 


For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at 202-204-1459/smadhani@mcdermottplus.com.

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