Medical rehabilitation focuses on improving or restoring
functional independence for individuals with disabilities
resulting from injury, illness or a medical condition.
Medical rehabilitation is provided at all levels of the health
care continuum, including general acute-care hospitals, inpatient
rehabilitation facilities (IRFs), skilled-nursing facilities,
long-term-care hospitals, outpatient programs and home health
agencies.
The Centers for Medicare & Medicaid Services (CMS) has posted
to its website the rate setting files for the inpatient
rehabilitation facility (IRF) prospective payment system proposed
rule for federal fiscal year 2014. The files, which include
average length of stay for case mix groups, are available
at
www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/Data-Files.html.
The Centers for Medicare & Medicaid Services (CMS) has
created a list of FAQs concerning therapy caps and use of the
advance beneficiary notice of non-coverage (ABN). The FAQs
address the requirements under the American Taxpayer Relief Act
of 2012 for therapists to issue ABNs for services that are not
medically necessary. A copy of the FAQs is attached.
The Centers for Medicare & Medicaid Services (CMS) has issued
the proposed rule for the inpatient rehabilitation facility (IRF)
prospective payment system (PPS) for federal fiscal year (FFY)
2014. Overall, CMS estimates that payments to IRFs will increase
2 percent, or approximately $150 million. The new rates will
apply to services furnished to Medicare beneficiaries during FFY
2014, beginning with discharges on or after Oct. 1, 2013. CMS
also proposes to remove a number of diagnosis codes from the list
used to determine a facility’s presumptive compliance with the
“60 percent rule.” In addition, the proposed rule includes three
new measures for the quality reporting program: 1) Percentage of
patients who were assessed and appropriately given the seasonal
influenza vaccine; 2) Influenza vaccination coverage among health
care personnel; and 3) An all-cause unplanned readmission measure
for 30 days post discharge. Revisions to the IRF patient
assessment instrument (IRF-PAI) to reflect new quality measure
reporting requirements are also proposed. CHA will issue a more
detailed summary, including facility-specific DataSuite reports,
of the proposed rule in the coming weeks. CHA will also work with
members to develop comments, which are due by July 1. The
proposed rule is attached and will appear in the May 8
Federal Register.
The Centers for Medicare & Medicaid Services (CMS) has
announced availability of the newest Program for Evaluating
Payment Patterns Electronic Report (PEPPER), with statistics
through September 2012. PEPPER summarizes provider-specific data
statistics for Medicare services that may be at risk for improper
payments, helping to support providers’ internal auditing and
monitoring activities. Visit www.pepperresources.org for
information on using the reports, including recorded web-based
training sessions, sample PEPPERs, user guides and FAQs.
The Centers for Medicare & Medicaid Services (CMS) has
announced that, effective April 1, recovery audit contractors
(RACs) will conduct prepayment reviews for Part B physical
therapy, occupational therapy, and speech/language pathology
services above the $3,700 threshold. Manual medical review of all
therapy services above this threshold is required by the
American Taxpayer Relief Act of 2012. In California, RACs will
conduct the mandated reviews on a pre-payment basis.When claims
for therapy services exceeding $3,700 are submitted, providers
will receive an additional development request from the Medicare
administrative contractor (MAC) unless an alternative process has
been established. The RAC will conduct the prepayment review
within 10 days of receiving the additional documentation and will
notify the MAC of the payment decision. CHA will host a webinar
March 27 from 10 a.m. – noon (PT) to provide practical advice and
direction on how to implement the new regulations, including
claims processing and denial management.
The Centers for Medicare & Medicaid Services (CMS) has issued
information outlining the interim process for manual medical
review for claims for therapy services that exceed the $3,700
threshold. The American Taxpayer Relief Act of 2012 extended the
manual medical review process for claims exceeding $3,700 for
physical therapy and speech/language pathology services, and/or
$3,700 for occupational therapy services per beneficiary per
year. CMS notes it is developing a long-term strategy
to deal with manual medical reviews. In the interim, Medicare
Administrative Contractors (MACs) will conduct pre-payment
reviews for claims above the threshold. CMS has requested that
MACs conduct the reviews within 10 days. At this time, there is
no process in place for an advance request of an
exception. For additional information, visit the CMS website
at
www.cms.gov/research-statistics-data-and-systems/monitoring-programs/medical-review/therapycap.html.
The Centers for Medicare & Medicaid Services (CMS) has issued
guidance regarding the multiple procedure payment reduction
(MPPR) for Medicare Part B physical therapy, occupational
therapy, and speech and language pathology services. Beginning
January 1, 2011, Part B therapy services provided in
institutional settings were subject to a 25 percent MPPR, applied
to the practice expense portion of the associated payment. The
American Taxpayers Relief Act of 2012 increased the MPPR to 50
percent effective April 1, 2013. A copy of the CMS transmittal is
attached.
The Centers for Medicare & Medicaid Services (CMS) has
revised the inpatient rehabilitation facility section of the
Medicare claims processing manual (Chapter 3, Section 140 of Pub.
100-04). According to CMS, the manual has been updated to reflect
regulatory changes that are in effect, streamline language and
improve readability. For details on the changes, see attached
change request.
The American Taxpayer Relief Act (ATRA) of 2012, signed into law
by President Obama last week, extends several provisions of
the Middle Class Tax Relief and Job Creation Act of 2012 that
impact therapy services provided by hospital outpatient
departments (HOPDs). The ATRA effectively extends applying
therapy caps to HOPDs through Dec. 31, 2013. Mandatory manual
medical review for Part B therapy services, which became
effective Oct. 1, 2012, for hospital and non-hospital therapy
providers, is also extended through Dec. 31, 2013, as a result of
the new law.
The Centers for Medicare & Medicaid Services (CMS) has
notified state survey agencies about new attestation statement
requirements for inpatient rehabilitation facilities (IRFs). Each
year IRFs must submit an attestation statement, using CMS form
437A or 437B, to verify they meet exclusion requirements from the
inpatient prospective payment system (IPPS) and may be reimbursed
under the IRF PPS system. Each attestation form must now include
additional information from the IRF’s medical director, who must
also cosign the form. Previously, only the hospital administrator
or CEO was required to sign the attestation. For more information
about the requirements, see attached CMS memorandum, revised
attestation forms and associated worksheets.
CHA has released a summary of provisions related to the inpatient
rehabilitation facility (IRF) quality reporting program
(QRP) that are included in the recently released Medicare
outpatient prospective payment system final rule. In the final
rule, CMS describes the update process for quality measures and
finalizes its proposal to retain all IRF QRP measures for federal
fiscal years 2014 and 2015. For more information, see attached
CHA summary.
The Centers for Medicare & Medicaid Services (CMS) will host
a conference call Dec. 12 on the new functional reporting
requirements for outpatient therapy services that go into effect
Jan. 1, 2013. The call will explain how to use the 42 new
nonpayable functional G-codes and seven new severity/complexity
modifiers on claims for Medicare Part B physical therapy,
occupational therapy and speech language pathology services. CMS
will also cover associated requirements for documenting medical
records. In addition, participants will have an opportunity to
ask questions. For more information and to register, go to
www.eventsvc.com/blhtechnologies.
Recordings of recent conference calls held by the Centers for
Medicare & Medicaid Services on the quality reporting
programs for inpatient rehabilitation facilities (IRFs) and
long-term-care hospitals (LTCHs) will be available July 30
through Aug. 1. Facilities may access the calls by dialing (855)
859-2056, and using conference IDs 13189170 for IRFs and 13198135
for LTCHs. As mandated by the Affordable Care Act, IRF and LTCH
quality reporting programs will begin Oct. 1.
The Centers for Medicare & Medicaid Services (CMS) will host
a series of monthly Open Door Forum (ODF) calls for the upcoming
implementation of the inpatient rehabilitation facility quality
reporting program. The calls will be held from 10 a.m. to 11:30
a.m. (PT) July 26, Aug. 16, Sept. 20 and Oct. 18, and will
include presentations on various topics with opportunities for
questions and answers. Providers may submit topic suggestions to
IRF.questions@CMS.hhs.gov.
For more information, go to
www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/index.html.
The Centers for Medicare & Medicaid Services (CMS) has issued
a proposed rule regarding the inpatient rehabilitation
facility (IRF) quality reporting program (QRP). The proposed rule
was included in the calendar year 2013 hospital outpatient
prospective payment system (OPPS) proposed rule issued July 6.
CHA’s “first-glance” summary of the OPPS and IRF QRP proposed
rules is available at www.calhospital.org/cy2013-opps-proposed-first-glance.
In the coming weeks, CHA will issue a more detailed summary of
the proposed rule, and will work with members to develop comments
for submission to CMS. Comments are due Sept. 4 at 2 p.m.
(PT).