The Centers for Medicare & Medicaid
Services (CMS) proposed Medicare regulations for acute hospitals, long-term
care hospitals (LTCH), and inpatient rehabilitation facilities (IRFs), to be
effective October 1, 2014. Of approximately 2,200 IRFs, about 2,000 are
certified units within acute hospitals.
Acute Hospitals and Long-Term
Care Hospitals (LTCHs)
The "2-Midnight Rule" classifies a patient as an
inpatient after having been in observation status for 2 nights. CMS notes that
suggestions regarding exceptions to the 2-Midnight rule can be sent to CMS via
written correspondence or e-mailed to [email protected]
with "Suggested Exceptions to the 2-Midnight Benchmark" in the subject line.
CMS is responding to suggestions through postings on the CMS website or manual
instruction, rather than in regulation. The feedback should address whether
there are "rare and unusual exceptions to the rule." Speech-language
pathologists and audiologists should understand that if a patient is not an
inpatient, then all Part B outpatient rules apply.
The payment update for
acute hospitals is proposed at 1.3%; the LTCH update is 0.8%.
The proposed payment increase is 2.1%.
CMS proposes to require the recording of how much and what type of therapy
patients receive per week, similar to the current SNF requirement. Beginning
with discharges on October 1, 2015, the IRF patient assessment instrument
(IRF-PAI) that has been in place since 2002 will include fields for individual,
group, or co-treatment minutes. The intent is to eventually determine an
appropriate limit to the amount of group therapy provided.
code list used for the "60% rule," which requires 60% of discharges to be from
a published list of diagnosis codes, will undergo mapping to ICD-10-CM but will
not go into effect until the October 1, 2015, ICD-10-CM conversion date. CMS
used the General Equivalence Mappings tool to convert ICD-9-CM to ICD-10-CM.
The proposed conversion can be found on the
FY 2015 IRF PPS Proposed Rule Data Files page.
The diagnoses include
stroke, spinal cord injury, brain injury, neurological disorders, and
Part A inpatient stays are paid for Medicare
beneficiaries under a Prospective Payment System (PPS), which sets payment
rates for inpatient stays based on a daily rate, diagnosis, and severity of
illness. Each setting has a payment classification and rate system that is
updated annually. The proposed rules are issued with a 60-day comment period,
are finalized, and go into effect in October.
Please contact the health care economics and
advocacy team at [email protected] for questions
regarding the proposed rules.