CMS announces FY 2022 Inpatient Rehabilitation Facility Prospective Payment System

April 8, 2021

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update Medicare payment policies and rates for facilities under the Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) and the IRF Quality Reporting Program (QRP) for fiscal year (FY) 2022. 

CMS is publishing this proposed rule consistent with the legal requirements to update Medicare payment policies for IRFs on an annual basis. 

Proposed Updates to IRF Payment Rates: 

For FY 2022, CMS is proposing to update the IRF PPS payment rates by 2.2% based on the proposed IRF market basket update of 2.4%, less a 0.2 %age point multi-factor productivity (MFP) adjustment. CMS is proposing that if more recent data becomes available (for example, a more recent estimate of the market basket or MFP adjustment), we would use these data, if appropriate, to determine the FY 2022 market basket update and MFP adjustment in the final rule. In addition, the proposed rule contains an adjustment to the outlier threshold to maintain outlier payments at 3.0% of total payments. This adjustment would result in a 0.3 percentage point decrease in outlier payments. We estimate that the overall increase to IRF payments for FY 2022 would be 1.8% (or $160 million), relative to payments in FY 2021. 

Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) proposed updates: 

The IRF QRP is a pay-for-reporting program. IRFs that do not meet reporting requirements are subject to a two-percentage point (2.0%) reduction in their Annual Increase Factor. CMS is proposing to adopt one measure and update the specifications for another measure. In addition, CMS is proposing a modification to the public reporting of IRF quality measures as well as seeking comment on two Requests for Information (RFI). 

Closing the Health Equity Gap – RFI: 

Consistent with Executive Order 13985 on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, CMS is committed to addressing the significant and persistent inequities in health outcomes in the United States through improving data collection to better measure and analyze disparities across programs and policies. CMS is working to make healthcare quality more transparent to consumers and providers, enabling them to make better choices as well as promoting provider accountability around health equity. CMS is seeking feedback in this RFI on ways to attain health equity for all patients through policy solutions. CMS’s ongoing commitment to closing the health equity gap in IRFs has been demonstrated by the adoption of standardized patient assessment data elements (SPADEs) which include several social determinants of health (SDOH) that were finalized in the FY 2020 IRF PPS final rule for the IRF QRP (84 FR 39149 through 39161). With this RFI, CMS is also seeking comment on the possibility of expanding measure development and the collection of other SPADEs that address gaps in health equity in the IRF QRP. 

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure: 

In the ongoing efforts to address the COVID-19 public health emergency, CMS is proposing the adoption of the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to require IRFs to report COVID-19 HCP vaccinations in their facilities. This proposed measure is designed to assess whether IRFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities, and help sustain the ability of IRFs to continue serving their communities through the public health emergency and beyond. 

Transfer of Health (TOH) Information to the Patient-PAC Quality Measure: 

CMS is proposing to update the denominator for the Transfer of Health (TOH) Information to the Patient-Post Acute Care (PAC) quality measure. Currently the measure denominators for both the TOH Information to the Patient-PAC and the TOH Information to the Provider-PAC measures include patients discharged home under the care of an organized home health service organization or hospice. In order to avoid counting the patient in both TOH measures, CMS is proposing to remove this location from the definition of the denominator for the TOH Information to the Patient-PAC measure. 

Public Reporting of Quality Measures with Fewer than Standard Numbers of Quarters Due to COVID-19 Public Health Emergency (PHE) Exemptions: 

In March 2020, due to the COVID-19 public health emergency, CMS granted an exception to the IRF QRP reporting requirements for Q1 2020 (January 1, 2020-March 31, 2020) and Q2 2020 (April 1, 2020-June 30, 2020). CMS also stated that any IRF QRP data that might be significantly impacted by these exceptions would not be publicly reported for Q1 and Q2 of 2020. This exception affected the standard number of quarters that CMS uses under to display IRF QRP data. CMS is proposing to update the number of quarters used for public reporting to account for this exception. 

For the refreshes to the Care Compare website affected by the quarters CMS excepted, we are proposing to calculate IRF QRP measures using three quarters (Q3 2020 through Q1 2021) of IRF QRP data for assessment-based measures, and six quarters for claims-based measures. CMS is proposing to use this methodology for the following affected refreshes: for the assessment-based measures, the affected refresh is the December 2021 refresh; for claims-based measures, the affected refreshes occur from December 2021 through June 2023, where the data will be updated in the December 2021 refresh (Q4 2018 through Q4 2019 and Q3 2020) and the September 2022 refresh (Q4 2019 and Q3 2020 through Q3 2021). For the earlier three affected refreshes (March, June and September 2021), CMS will hold constant the Care Compare website with December 2020 data. 

Fast Healthcare Interoperability Resources (FHIR) in Support of Digital Quality Measurement in Post-Acute Care Quality Reporting Programs – RFI: 

CMS is working to further the mission to improve the quality of healthcare for beneficiaries through measurement, transparency and public reporting of data. The IRF QRP and CMS’s other quality programs are foundational for contributing to improvements in healthcare, enhancing patient outcomes, and informing consumer choice. CMS believes that advancing our work with use of the FHIR standard offers the potential for supporting quality improvements and reporting, which will improve care for our beneficiaries. CMS is seeking feedback on our future plans to define digital quality measures (dQMs) for the IRF QRP. CMS also is seeking feedback on the potential use of FHIR for dQMs within the IRF QRP, aligning where possible with other quality programs. 

CMS has the fact sheet

More COVID-19 coverage HERE.