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CMS' Final Rule is Here!

Tuesday was the day! On July 30, CMS released the FY 2020 Final Rule for Medicare payment rates and quality programs. This is the moment we have all been waiting for. PDPM is 9 short weeks away, and the industry finally has clarifications RE: the new payment model.

Not much has changed since the Proposed Rule released April 2019, but count on HealthPRO® Heritage to summarize the updates to the Final Rule here:

Updates Related to PDPM
IPA versus IMA
Is it official that the 5–day will be called the “initial patient assessment?” Will we have two “IPAs”?  The answer is “NO;” we will not. Instead, CMS chose to call the 5-day: “initial Medicare assessment.”  (And only time will tell whether the acronym “IMA” will stick.)

What a Relief
The ARD must be set by Day 8, but the IMA will NOT need to be completed by Day 8 post-hospital stay.  

A Little Help
CMS will establish a process to assure all ICD-10 mappings are the most up-to-date lists because of how important these details are in determining non-therapy ancillary points and clinical category mapping for the PT, OT, and SLP components.

Group Therapy Update 
CMS is defining Group Therapy for Outpatient and Inpatient Rehab Facilities (IRFs) as including two to six patients. This change signifies another step closer to a future unified payment system, reduces burden by using the same definition across post-acute care (PAC) settings, and allows SNFs with small skilled census to conduct group therapy with as few as two residents (versus currently requiring four residents).

To IPA or Not to IPA?
Further clarification was provided regarding the “optional” Interim Payment Assessment (aka: “IPA”). The statement from the federal register of the Final Rule (see below) and may be construed very differently than how the industry originally interpreted it. Stay tuned for more feedback and strategy from HealthPRO® Heritage on this topic!

“We note that while a SNF’s decision to complete the IPA itself is indeed optional, the SNF’s underlying responsibility to remain fully aware of (and respond appropriately to) any changes in its resident’s condition is in no way discretionary. Moreover, the discussion of the IPA in the FY 2019 SNF PPS final rule (83 FR 39233) clearly envisions a role for this assessment that is not strictly limited to payment alone: “We continue to believe that it is necessary for SNFs to continually monitor the clinical status of each and every patient in the facility regularly regardless of payment or assessment requirements and we believe that there should be a mechanism in place that would allow facilities to do this.” At the same time, in making the IPA optional, we recognized “. . . that providers may be best situated, as in the case of the Significant Change in Status Assessment, to determine when a change has occurred that should be reported through the IPA.” (84 FR 39233)

Updates that Impact Beyond PDPM

  • SNFs will receive a 2.4% market basket increase for FY 2020 starting in October of 2019, representing an aggregate increase over $851 million dollars to our industry.
  • The SNF Value Based Purchasing Program (VBP) is expected to:
    • Adopt a new name for the program’s potentially preventable readmission measure, and
    • Update the public reporting requirements for CMS to publish accurate performance info for low volume SNFs and a new 30 day deadline for Phase One Review and Corrections requests.
  • SNF Quality Reporting Program (QRP) - CMS adopted two transfer of Health Information Quality Measures and standardized patient assessment data elements that will begin reporting with admissions and discharges that occur on or after October 1, 2020.  (Not this year. Phew!)
    • Good news for SNF providers: baseline nursing home residents will be excluded from the discharge to community measure (which can skew the overall percentage)
    • Being finalized: public display of the Quality Measure, Drug Regimen Review Conducted with Follow Up for Identified Issues
    • CMS has unfortunately decided not to expand data collection for the SNF QRP to all SNF residents regardless of their payor. (Consider the continued growth of more than 30% patients that carry Medicare Advantage – a payor with very little data available. )

On Another Note: CAH Update
CMS will continue to exclude swing-beds at Critical Access Hospitals (CAHs) from SNF PPS, but SNF-level services provided under a swing-bed agreement will continue to be subject to SNF PPS payment methodologies.

Beyond PDPM, Beyond Therapy
HealthPRO® Heritage is a trusted consultative partner leading the industry in PDPM readiness. We are here to support you with strategy, education, and execution on key clinical competencies that are crucial to PDPM success. Contact us at info@healthpro-heritage.com with any questions. 

Tags: The Final Rule, Patient-Driven Payment Model, PDPM, CMS Update 2019