CMS finalized increases to all key post-acute payment systems (LTACH, IRF and SNF), as well as Hospice and Inpatient Psych. The finalized rules also made changes to key post-acute areas to provide greater alignment between providers and support continued movement toward a unified payment system. The following text provides key updates for each of these key areas. These actions by CMS signal continued strong support for post-acute care venues and their ongoing importance to America’s healthcare continuum.

➢   Long Term Acute Care Hospital Payment Increase Update

CMS to increase discharge payments by 2.5% for patients reimbursed under LTC PPS. The FY20 LTACH PPS Standard (Unadjusted) Federal Payment Rate rises to $42, 677.64 (adjusted rate: $42,140.77).

The site neutral payment transition period for cost reporting periods that continued through FY19 will end under the new rules. As such, discharges for cost reporting periods beginning in FY20 will be reimbursed under the site neutral payment rate. The blended rate used during the transitional period will no longer apply. The final rule also provides for a cure period for those LTACHs not meeting the minimum 50% requirement for patients meeting LTACH criteria.

♦  LTACH Quality Reporting Program

In FY2020 CMS is finalizing the adoption of  two new quality measures relating to the transfer of health information:

  • Transfer of Health Information to the Provider- Post Acute Care (PAC), and
  • Transfer of Health Information to the Patient- Post Acute Care (PAC).

CMS is also proposing the adoption of standardized patient assessment data elements (SPADE), including:

  • Functional status,
  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
    • Race and Ethnicity,
    • Preferred Language and Interpreter Services,
    • Health Literacy,
    • Transportation, and
    • Social Isolation.

Additionally, CMS will update the Discharge to Community LTCH QRP measure to not include nursing home residents.

➢   Inpatient Rehabilitation Facility Payment Increase Update

In FY20, CMS is increasing IRF rates 2.53% over the FY19 rates. The final Rehabilitation (IRF) FY20 Standard Payment Base Rate Conversion Factor is $16,573. CMS is finalizing change to the case mix groups (CMGs) based on quality indicator data to start in FY20. CMS will use data from FY17 and FY18 to adjust relative weights and length of stay. In contrast to the proposed rule, CMS will use an unweighted (versus proposed weighted) motor score to ease the transition in FY20.

♦  Rehabilitation Physician

The final rules amend the regulations to permit the individual IRF to determine whether a physician qualifies as a “rehabilitation physician”.

♦  Quality Reporting Program 

CMS finalized two new quality measures in FY2020:

  • Transfer of Health Information from IRF to another Provider; and
  • Transfer of Health Information from IRF to the Patient.

CMS is also adopting of standardized patient assessment data elements (SPADEs) that assess the following:

  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
    • Race and Ethnicity,
    • Preferred Language and Interpreter Services,
    • Health Literacy,
    • Transportation, and
    • Social Isolation.

Additionally, CMS will update the Discharge to Community IRF QRP measure to not include nursing home residents. Further, in response to comments received regarding using IRF, PAI to calculate quality measure on all patients regardless of payer, CMS will not finalize rule as proposed.

➢   Skilled Nursing Facility Payment Increase Update

CMS is proposing a 2.45% increase in FY20 over the previous year’s reimbursement. Effective October 1, 2019, the Patient Driven Payment Model (PDPM) will replace the Resource Utilization Group (RUG) as planned.  Utilizing ICD-10 codes for patient classification, this new structure will focus on the value, and not the volume, of care provided within a patient’s SNF stay.  Under this rule CMS is finalizing use of a sub-regulatory process for making updates to the ICD-10, a process similar to that used under the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS).

In addition to the above, CMS is finalized a change in the definition of group therapy for SNFs. While currently defined as “four patients”, CMS is adopting to adopt the same definition used within the IRF PPS of “two to six patients” undergoing similar activities. Again, the change demonstrates a concerted effort toward establishing consistency among post-acute care providers.

♦  Quality Reporting Program 

In a continued push for increased quality, CMS finalized the addition of two new quality measures in FY2020:

  • Transfer of Health Information to the Provider-Post-Acute Care; and
  • Transfer of Health Information to the Patient- Post- Acute Care.

In addition, CMS is adopting standardized patient assessment data elements (SPADE) to assess the following:

  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
    • Race and Ethnicity,
    • Preferred Language and Interpreter Services,
    • Health Literacy,
    • Transportation, and
    • Social Isolation.

Additionally, CMS will update the Discharge to Community SNF QRP measure to not include nursing home residents. Further, in response to comments received regarding collecting SNF QRP data on all patients regardless of payer, CMS will not finalize rule as proposed.

♦  Value Based Purchasing

On October 1, 2018, SNFs began receiving incentive payments based on quality performance under an all-cause measure of hospital readmissions. CMS will change the name of this measure to “Skilled Nursing Facility Potentially Preventable Readmission after Hospital Discharge”, which maintains the acronym SNFPPR.

CMS also finalized the proposed changes in the requirements for SNFs with less than 25 eligible cases during a baseline period or those with zero eligible cases during a program year.

In addition, CMS is looking to adopt standardized patient assessment data to assess the following:

  • Cognitive function and mental status,
  • Special Services,
  • Treatments and Interventions,
  • Medical Conditions and Comorbidities,
  • Impairments,
  • Social Determinants of Health,
  • Race and Ethnicity,
  • Preferred Language and Interpreter Services,
  • Health Literacy,
  • Transportation, and
  • Social Isolation

➢   Hospice Payment Increase Update

While not part of the proposed Unified Post-Acute Payment System, Advis provides the following update to Hospice providers.

CMS finalized a 2.67%  increase to the Hospice payment rates under FY20. The finalized annual cap for Hospice payments for any one patient will be $29,964.78 Under the FY20 final rules, CMS increased rates for Continuous Home Care (CHC), General Inpatient Care (GIP), and Inpatient Respite Care (IRC). For budget neutrality, CMS finalized a reduction in payment rates for Routine Home Care (RHC). The change is in response to a need to right size reimbursement with cost of care.

CMS finalized an amendment to the election statement required of Hospice patients to include a rationale for items deemed unrelated to the terminal illness.  This change, which will go into effect October 1, 2020 is to ensure those patients electing Hospice care are doing so in an informed manner.

♦  Hospice Quality Reporting Program

CMS will continue data collection on “Hospice Visits over the Last 7 Days”, but will not publish data related to this measure. CMS will instead review data to determine the need for any additional changes prior to publication.

➢   Inpatient Psychiatric Facilities Payment Increase Update

Under the FY20 IPF final rules, CMS is increasing the Psychiatric (IPF PPS) of 1.57% making the Federal per diem base rate $798.55. For the market basket update, CMS is utilizing the 2016 base year instead of 2012. Within these final rules, CMS is also removing the one year lag of the wage index data for FY 2020 moving forward.

♦  IPF Quality Reporting Program

In FY20, CMS is adding one new measure to begin in FY21 entitled Medical Continuation Following Inpatient Psychiatric Discharge.  This measure will track whether patients with Major Depressive Disorders, Schizophrenia or Bipolar Disorder fill at least one medication within two days before or 30 days after discharge following admission to an Inpatient Psychiatric Facility.

Conclusion

All rules, unless otherwise stated, go into effect October 1, 2019. Advis is a national expert in post-acute care services. Advis can assist providers in determining how final rules may impact your facility, or help in exploring interest in establishing a post-acute care venue that may be beneficial to your organization.

For more information on how Advis can help your organization, please call our office at (708) 478-7030 or contact us at www.advis.com/contact.