CMS Adopts IRF Final Rule for Fiscal Year 2012
The Centers for Medicare and Medicaid Services (CMS) has issued its final regulation for inpatient rehabilitation facilities (IRFs) for fiscal year 2012. Click here to read the final IRF rule.
The final rule updates the payment rates for IRFs for fiscal year 2012 with an increase of approximately $150 million (or +2.2%) and establishes a new quality reporting system. Beginning October 1, 2012, IRFs will submit data for the calculation of two measures: a urinary catheter-associated urinary tract infection measure and a measure for new or worsening pressure ulcers. IRFs that do not comply with the new program will see their payments reduced by 2 percentage points beginning in FY 2014. CMS anticipates adding quality measures to the reporting program in future years through rulemaking, and currently has under development a third measure, “30-day Comprehensive All Cause, Risk Standardized Readmission.” The final rule is effective October 1, 2011.
CMS Press Release: CMS Implements Payment, Policy Changes for Inpatient Rehabilitation Facilities
CMS Fact Sheet: Policy and Payment Rate Updates for Inpatient Rehabilitation Facilities in Fiscal 2012
AOTA submitted comments on the proposed IRF rule. We advocated for quality measures that measure all areas integral to the needs of the patients addressed by IRFs, including occupational therapy. We stated that AOTA does not believe that the current list of Possible Future Measures and Topics for the IRF Quality Reporting Program is comprehensive enough. We urged CMS to allow the IRF Quality Measure Technical Expert Panel (TEP) time to identify and develop quality measures before moving forward with CMS’ own measures without input from the TEP. We expressed concern about the use of the Continuity Assessment Record & Evaluation (CARE) tool in a setting for which it was not intended and urged CMS to refine the CARE tool before using it in IRFs. We advised that CMS should test and validate the use of any instrument to assess quality or outcomes. We mentioned other tools/tests that may be appropriate for IRF patients. We also encouraged CMS to take another look at the management of pressure ulcers in IRFs. We asked CMS to continue to support the occupational therapist’s professional judgment as the foremost consideration in making the determination as to the most appropriate mode of delivery of occupational therapy services to individual patients based on the therapy plan of treatment.