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What's New FAQs Frequently Asked Questions for the Describing Function Team Read more >> Free Education Module ICF Education Modules for Rehabilitation Click here to download >> New Regulation Article Proposed Rule Emphasize the Important Role of Information Systems and Rehabilitation Physicians. Read more >>	New Regulation Article The Medicare Hospital Conditions of Participation and the FY 2010 Inpatient Rehabilitation Facility (IRF) Proposed Rule Emphasize the Important Role of Information Systems and Rehabilitation Physicians. The information health care organizations collect in their health records must support multiple functions, including the delivery of personal health services, quality assurance and performance improvement, reimbursement and administrative decision-support. The Centers for Medicare & Medicaid Services (CMS), through its Hospital Conditions of Participation (COPs), requires hospitals participating in the Medicare program to develop an effective Quality Assessment and Performance Improvement (QAPI) program (1). CMS has recognized the importance of information technology in the delivery of quality health care services and therefore permits one of the required performance improvement projects to be the development of an information system explicitly designed to improve safety and quality of care (2). The Medicare program contains an Inpatient Rehabilitation Facility (IRF) benefit. The IRF benefit is designed to provide intensive rehabilitation services in a resource intensive environment for patients who have experienced an acute impairment. Typically patients are transferred to an IRF following an acute inpatient hospitalization, as part of the post-acute care continuum. Patients qualifying for the Medicare IRF benefit must require, and be expected to benefit significantly from, intensive rehabilitation provided through a coordinated interdisciplinary team approach implemented in an inpatient hospital environment. The Medicare IRF benefit prohibits the provision of services by, and the reimbursement of services to, an IRF if those services could have been provided in a less intensive post-acute setting such as a skilled nursing facility (SNF)(3). CMS has established “the right care for every person every time” as one of its guiding principles. One of the ways it monitors this guiding principle is through the Permanent Recovery Audit Contractor (RAC) Program. The goal of the RAC program is to detect and correct improper payments within the Medicare Fee-For-Service (FFS) Program, and by so doing, promote process improvements on both the Medicare provider and payer sides of the equation. The RAC program is therefore expected to both detect past improper payments and prevent future improper payments by promoting preventive actions by Medicare providers and contractors, the latter being responsible for payment of Medicare FFS claims (4). The RAC was preceded by a 3 year demonstration program that identified $1.03 billion in improper Medicare payments. As of March of 2008 $59.7 million had been collected from IRF providers - principally in California and for the payment error category “medically unnecessary service or setting” (5). This observation prompted CMS to propose a change in its regulations governing IRF services and its instructions to Medicare contractors on the coverage and payment of IRF services. (6)(7) A total of 1,205 IRF providers in the US will be impacted by the regulatory changes contained in the proposed rule (8) . One of the most potentially challenging aspects of the regulatory change is the formal expectation that rehabilitation physicians will be held accountable for ensuring the data integrity and decision-making associated with the IRF pre-admission, admission and care-planning processes. While the proposed rule deems these requirements to be in keeping with existing Hospital COPs, many IRF providers will need to implement new processes to ensure compliance. The regulatory changes contained in the proposed rule are intended to develop a clear understanding among stakeholders of the IRF benefit, especially as it relates to the Medicare coverage available in less intensive, post-acute care settings. CMS defines the post-acute care environment as including IRF, SNFs, Long-term Care Hospitals (LTCH), and Home Health Agencies (HHA). Administrative data collection and reporting methods vary in each of these environments, as do physician documentation requirements. The fundamental unmet need is, therefore, a transparent method of communicating the health status of individual’s being considered for IRF services - a method that is understood by all post-acute stakeholders. Using the concepts of the International Classification of Functioning, Disability and Health (ICF), the Describing Function team is working with IRF providers and rehabilitation physicians to evaluate and continuously improve the quality of the data in their health records. For more information on how the Describing Function team and the ICF can be used to help ensure compliance with the Hospital COPs and the proposed regulatory changes please contact us. United States Code of Federal Regulation Title 42 § 482.21 United States Code of Federal Regulation Title 42 § 482.21(d)(2) Medicare Benefit Policy Manual, Chapter 1, Section 110 Inpatient Rehabilitation Facility Services www.cms.hhs.gov/manuals/Downloads/bp102c01.pdf www.cms.hhs.gov/RAC/Downloads/RAC%20Evaluation%20Report.pdf www.cms.hhs.gov/RAC/Downloads/RAC%20Evaluation%20Report.pdf http://edocket.access.gpo.gov/2009/pdf/E9-10078.pdf www.cms.hhs.gov/InpatientRehabFacPPS/Downloads/Revised_Section_110_MBP_Manual_DRAFT_for_Comment.pdf edocket.access.gpo.gov/2009/pdf/E9-10078.pdf
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The Medicare Hospital Conditions of Participation and the FY 2010 Inpatient Rehabilitation Facility (IRF) Proposed Rule Emphasize the Important Role of Information Systems and Rehabilitation Physicians.

The information health care organizations collect in their health records must support multiple functions, including the delivery of personal health services, quality assurance and performance improvement, reimbursement and administrative decision-support. The Centers for Medicare & Medicaid Services (CMS), through its Hospital Conditions of Participation (COPs), requires hospitals participating in the Medicare program to develop an effective Quality Assessment and Performance Improvement (QAPI) program (1). CMS has recognized the importance of information technology in the delivery of quality health care services and therefore permits one of the required performance improvement projects to be the development of an information system explicitly designed to improve safety and quality of care (2).

The Medicare program contains an Inpatient Rehabilitation Facility (IRF) benefit. The IRF benefit is designed to provide intensive rehabilitation services in a resource intensive environment for patients who have experienced an acute impairment. Typically patients are transferred to an IRF following an acute inpatient hospitalization, as part of the post-acute care continuum. Patients qualifying for the Medicare IRF benefit must require, and be expected to benefit significantly from, intensive rehabilitation provided through a coordinated interdisciplinary team approach implemented in an inpatient hospital environment. The Medicare IRF benefit prohibits the provision of services by, and the reimbursement of services to, an IRF if those services could have been provided in a less intensive post-acute setting such as a skilled nursing facility (SNF)(3).

CMS has established “the right care for every person every time” as one of its guiding principles. One of the ways it monitors this guiding principle is through the Permanent Recovery Audit Contractor (RAC) Program. The goal of the RAC program is to detect and correct improper payments within the Medicare Fee-For-Service (FFS) Program, and by so doing, promote process improvements on both the Medicare provider and payer sides of the equation. The RAC program is therefore expected to both detect past improper payments and prevent future improper payments by promoting preventive actions by Medicare providers and contractors, the latter being responsible for payment of Medicare FFS claims (4).

The RAC was preceded by a 3 year demonstration program that identified $1.03 billion in improper Medicare payments. As of March of 2008 $59.7 million had been collected from IRF providers - principally in California and for the payment error category “medically unnecessary service or setting” (5). This observation prompted CMS to propose a change in its regulations governing IRF services and its instructions to Medicare contractors on the coverage and payment of IRF services. (6)(7)

A total of 1,205 IRF providers in the US will be impacted by the regulatory changes contained in the proposed rule (8) . One of the most potentially challenging aspects of the regulatory change is the formal expectation that rehabilitation physicians will be held accountable for ensuring the data integrity and decision-making associated with the IRF pre-admission, admission and care-planning processes. While the proposed rule deems these requirements to be in keeping with existing Hospital COPs, many IRF providers will need to implement new processes to ensure compliance.

The regulatory changes contained in the proposed rule are intended to develop a clear understanding among stakeholders of the IRF benefit, especially as it relates to the Medicare coverage available in less intensive, post-acute care settings. CMS defines the post-acute care environment as including IRF, SNFs, Long-term Care Hospitals (LTCH), and Home Health Agencies (HHA). Administrative data collection and reporting methods vary in each of these environments, as do physician documentation requirements. The fundamental unmet need is, therefore, a transparent method of communicating the health status of individual’s being considered for IRF services - a method that is understood by all post-acute stakeholders.

Using the concepts of the International Classification of Functioning, Disability and Health (ICF), the Describing Function team is working with IRF providers and rehabilitation physicians to evaluate and continuously improve the quality of the data in their health records. For more information on how the Describing Function team and the ICF can be used to help ensure compliance with the Hospital COPs and the proposed regulatory changes please contact us.