CMS Proposed Rule: Key Concerns

By Kindred Hospital Rehabilitation Services

Kindred recently commented on Medicare’s 2020 proposed rule for freestanding and hospital-based inpatient rehabilitation facilities (IRFs). The response was consistent with Kindred’s mission to help patients reach their highest potential for health and healing with intensive medical and rehabilitative care through a compassionate patient experience.

Generally, the proposed rule was in line with expectations, but there were areas that Kindred wanted to address to ensure a smooth operating environment and that IRFs are available to best meet the rehabilitative and medical care needs of patients.

In its comments, Kindred highlighted concerns with the proposal which would have a negative impact on IRFs and their unique ability to provide the necessary intensive rehabilitation services to clinically complex patients. Specifically, Kindred believes the proposed Case-Mix Group (CMG) changes would have a negative impact on patient access to intense rehabilitation services. For example, Kindred has concerns with the huge shifts in the proposed weighting of the motor score, the increased payments for lower acuity patients, and the significant redistribution in payments – impacts on individual hospitals ranging from a 17% increase to a 27% decrease – that occurs as a result of the new CMGs.

Within the response, Kindred recommended that the Centers for Medicare and Medicaid Services (CMS) delay implementation and conduct additional work in order to validate that the CMGs reimburse IRF providers sufficiently for the more functionally impaired patients before implementing the proposed changes.

Kindred recommended that during the delay, CMS should continue to align the motor score weights with those used under the Functional Independence Measure (FIM™) until additional analyses are performed to validate the accuracy of the weights for the highest acuity, most functionally impaired IRF patients.

CMS Proposed Rule: Key Concerns

We emphasized that prior to making such substantial changes, CMS must take time to ensure that any proposed changes do not impede patient access to necessary rehabilitation services.

Kindred also recommended that CMS consider ways to streamline the new reporting requirements or eliminate some of the current requirements – so there is no net addition in administrative burden, in line with the Administration’s goal to streamline regulations.

For more information on the proposed rule, check out another recent blog post and to learn how it could impact your hospital’s rehab program and how you can prepare, contact us today.