Minimal Change to Most Post-Acute Venues Under CMS FY21 Final Rules

During this time of crisis, Medicare has issued its final rules with a focus on areas required by statute, on providing updates to payment rates, and on actions to reduce provider burden. The following rules are applicable to discharges within the CMS Fiscal Year of October 1, 2020- September 30, 2021.

The reporting below covers the areas of Inpatient Rehabilitation Facilities (“IRF”), Hospice, Skilled Nursing Facilities (“SNF”), and Inpatient Psychiatric Facilities (“IPF”). Positive payment updates occur in all areas noted, ranging from 2.2% to 2.8%.  No updates to the Quality Reporting Program noted below occurred in one area. At the time of writing, the final rules for Long Term Acute Care Hospitals have not yet been released. Advis will provide updates once they’re available.

Inpatient Rehabilitation Facilities

The Centers for Medicare and Medicaid Services (CMS) have issued the FY 2021 Inpatient Rehabilitation Facility Prospective Payment System (“IRF PPS”) final rules.   Under these rules, CMS continues to reduce provider burden while increasing IRF payment rates under the IRF PPS.

  • Expanding Performance of Non-Physician Practitioners

Within this year’s proposed changes, CMS proposed to allow non-physician practitioners (NPPs) to perform IRF facility coverage requirements, as long as their duties fall within the NPPs scope of practice. The proposal included IRF coverage services and documentation that must currently be performed by a rehabilitation physician.

However, the rules were not finalized as proposed. The final rules permit NPPs to conduct one of the three face to face physician visits in the second and subsequent weeks of the patient’s stay as long as that visit is within the NPP scope of practice. The rules do not change the requirement that a physician review/approve the pre-admissions screening assessment, develop the individualized plan of care, and lead the interdisciplinary team meetings.

  • Eliminating the Post-Admission Physician Evaluation

In an effort to correct what is currently seen as a redundant exercise, CMS has permanently eliminated the post-admission physician evaluation requirement. As there are other documentation requirements that cover the same information, this change allows providers the flexibility to see patients within the first 24 hours based on patient condition, but no longer under the mandate currently in place.

  • Payment Updates

CMS will increase IRF PPS payment rates by an overall update of 2.8% over the FY2020 payment rates. CMS has also finalized the revised geographic delineations by the OMB to calculate wage index and the application of a 5% cap on wage index decreases from FY20 to FY21.

  • Quality Reporting

CMS is not making any changes to the IRF Quality Reporting Program for FY2021.

Hospice

The Centers for Medicare and Medicaid Services (CMS) have issued the FY 2021 Hospice Payment Update. As with other post-acute venues, the focus of this year’s rules has been on mandated updates during this public health emergency.

  • Payment Update

In the FY21 final rules, CMS has finalized an increase to Hospice payments of 2.4%. The aggregate cap limit for FY21 is $30,683.93 to reflect the 2.4% increase from FY20 to FY21.

CMS has also finalized the revised geographic delineations by the OMB to calculate wage index and the application of a 5% cap on wage index decreases from FY20 to FY21.

  • Hospice Election Statement

To assist providers, CMS is providing links to sample hospice election statements as well as an addendum which becomes effective in FY20.

Skilled Nursing Facilities

The Centers for Medicare and Medicaid Services (CMS) have issued the FY 2021 Skilled Nursing Facility Prospective Payment System (“SNF PPS”) final rules.   Under these rules, CMS continues to reduce provider burden, while increasing SNF payment rates under the SNF PPS.

  • SNF PPS Payment Updates

CMS will increase SNF PPS payment rates by an overall 2.2% over FY2020 payment rates. CMS has finalized the application of a 5% cap on wage index decreases.

  • Updates to the Patient Driven Payment Model (PDPM)

In this final rule, CMS has finalized updates to ICD-10 code mapping for classifying patients under PDPM. These changes result from feedback and recommendations made by providers. CMS encourages continued comments to improve this newly implemented payment structure.

  • SNF Value Based Purchasing (VBP) Program Updates

Under the FY21 Final SNF rule, no changes are made to the VBP measures, scoring, or payment policies. These rules only update the regulations at 42 CFR 413.338 to reflect previously finalized policies; they also update the 30-day Phase One Review and Correction deadline for baseline quality measure reports.

Inpatient Psychiatric Facilities (IPF)

The Centers for Medicare and Medicaid Services (CMS) have issued final rules for the FY 2021 Inpatient Psychiatric Facility Prospective Payment System (“IPF PPS”). Under these rules, CMS continues to reduce provider burden while increasing IPF payment rates under the IPF PPS.

  • IPF PPS Payment Updates

CMS will increase IPF PPS payment rates by an overall update of 2.3% over the FY2020 payment rates. The base rate per diem for FY 21 will increase from $798.55 to $815.22. A 2% reduction occurs for providers failing to submit quality data. Under these final rules the fixed dollar loss threshold will go from $14,960 to $14,630.

CMS has also finalized the revised geographic delineations by the OMB to calculate wage index and the application of a 5% cap on wage index decreases from FY20 to FY21.

  • Regulatory Changes

To reduce burden on inpatient psychiatric facilities, CMS is revising current language to permit advance practice providers to document in a patient’s medical record who they are treating for as long as permitted within state scope of practice. Advance practice providers include physician assistants, nurse practitioners, psychologists and clinical nurse specialists.

  • IPF QRP

There were no updates to the IPF QRP for FY21.

For further guidance or any other inquiries, please reach out to the experts at Advis online or by calling 708-478-7030.

Published: August 25, 2020