The Centers for Medicare and Medicaid Services has upped inpatient rehab facilities payments by 2.4%, in 2021, in a final rule updating the Inpatient Rehabilitation Facility Prospective Payment System.
Additionally, CMS is increasing aggregate payments by 0.4% to maintain outlier payments at 3% of total payments, resulting in an overall update of 2.8% or $260 million for FY 2021.
The final rule also applies a 5% cap on wage index decreases from 2020 to 2021, which aligns with recent Office of Management and Budget statistical area delineations.
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Other provisions relate to coverage requirements and physician evaluation requirements and follow the legal mandate to update Medicare payment policies for IRFs every year.
WHAT'S THE IMPACT
The first provision updates and codifies existing documentation instructions and guidance related to Medicare IRF coverage requirements.
For a claim to be considered reasonable and necessary, there must be a reasonable expectation that the patient meets all of the IRF coverage requirements at the time of the patient's admission to the IRF. The new provision clarifies and reduces the administrative burden on both IRF providers and Medicare Administrative Contractors when making a patient claim, according to CMS.
The next rule permanently eliminates the need for a post-admission physician evaluation, effective October 1.
Prior to the COVID-19 pandemic, IRFs were required to conduct a post-admission physician evaluation within the first 24 hours of a patient's admission to confirm that no changes had occurred. During the pandemic, a new policy didn't require post-admission evaluations because much of the information is included in the pre-admission screening documentation. Now, the flexibility will be granted beyond the expiration of the public health emergency.
The final rule also allows non-physician practitioners to perform one of the three required visits in lieu of the physician in the second and later weeks of a patient's care, when consistent with the non-physician practitioner's state scope of practice.
CMS currently requires physicians to meet with their patients three times a week to make sure the patient's care plan is on track. The new rule allows non-physician practitioners to remove some of the burdens from physicians. Physicians are still required to review and agree with the preadmission screening, establish the care plan and lead weekly interdisciplinary team conferences.
THE LARGER TREND
The final rule is slightly different from what was proposed in April.
Originally, CMS planned for an overall update of 2.9%, or $270 million for FY 2021.
The proposed rule did include the 5% cap on wage index decreases from 2020 to 2021, the provision that allowed non-physician practitioners to perform patient visits and the elimination of post-admission physician evaluations.
The final rule further advances the department's effort to strengthen the Medicare program by better aligning payments for inpatient rehabilitation facilities, according to CMS.
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