Final 2014 IRF Rule

On July 31, 2013, the Centers for Medicare and Medicaid Services (CMS) issued the final 2014 Medicare payment and regulatory update for Inpatient Rehabilitation Facilities, which includes a 2.3 percent increase in Medicare payments effective on October 1, 2013. The final rule also included several updates including changes to the list of diagnosis codes that are used to determine presumptive compliance with the “60 Percent Rule,” changes to the IRF Patient Assessment Instrument (IRF-PAI), and revised quality measures and reporting requirements.

We were pleased that in preparing the final rule, CMS took into consideration some of the formal comments that KHRS and other stakeholders provided. While we had specifically advocated CMS withdraw the proposed changes to the presumptive compliance criteria methodology, we also commented that if CMS decides to move forward with the changes, it should allow providers adequate time for implementation, establish modifiers for arthritis, appropriately target record review, and preserve certain codes. In an improvement over the proposed rule, and consistent with our comments, CMS has removed fewer codes than originally proposed from those that may count toward presumptive compliance of the 60% Rule threshold. Additionally, this portion of the update will not take effect until October 1, 2014, which gives providers time to prepare.

The changes to the IRF-PAI and to the IRF quality reporting program are also delayed by a year, effective as of October 1, 2014.

By Kindred Hospital Rehabilitation Services