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The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on April 21, 2008 that would update payment rates for services furnished to Medicare patients in inpatient rehabilitation facilities (IRFs), effective for discharges on or after October 1, 2008. The proposed rule would apply to more than 200 freestanding IRFs, and to more than 1,000 IRF units in acute care hospitals.
In order to be excluded from the acute care hospital payment system and instead be paid the higher rates for providing rehabilitation services as an IRF, the facility must demonstrate that its annual patient population consists of at least 60 percent of patients with one or more of the qualifying conditions listed below. The 60 percent threshold, as opposed to 75 percent, is a major modification mandated by the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA). The law also requires CMS to continue the use of specified comorbidities (i.e., secondary diagnoses) in addition to the patient's primary reason for being in the IRF when determining the 60 percent compliance level.
Speech-language pathologists employed in IRFs may be disappointed that the MMSEA does not allow payment increases in FY2008 or FY2009. However, the diminished restrictions on patient diagnoses allow IRFs to admit patients that may have been denied under the 75 percent rule.
As always, cases with extraordinarily high costs compared to the prospectively set payment may qualify for an outlier payment. However, due to the statutory elimination of FY2008/ FY2009 payment increases, CMS calculated a need to reduce estimated outlier payments from 3.3 percent for FY2008 to 3.0 percent for FY2009. This proposed change will result in an estimated decrease in aggregate IRF payments of $20 million for FY2009.
Patients who have one or more of the following conditions as the primary reason for receiving treatment in the IRF or as a qualifying comorbidity may be counted toward an IRFs compliance percentage to qualify for the 60 percent rule.
- Stroke
- Spinal cord injury
- Congenital deformity
- Amputation
- Major multiple trauma
- Fracture of femur (hip fracture)
- Brain injury
- Neurological disorders
- Burns
- Arthritis-related medical conditions (three types specified in the rule)
- Knee or hip joint replacement if (1) it was bilateral, (2) the patient's BMI was greater than 50, or (3) the patient was 85 or older
Comments will be accepted on the proposed rule until June 20, 2008 and CMS will respond to comments in a final rule to be issued on or before August 1. The complete proposed rule is found at on the CMS Web site. For further information, please contact Mark Kander, ASHA's Director of Health Care Regulatory Analysis, at mkander@asha.org or by phone at 800-498-2071, ext. 5669.
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