PPS Takes Effect in Impatient Rehabilitation Facilities On Jan. 1, an important change took effect at many rehabilitation facilities—the implementation of the Inpatient Rehabilitation Facility Prospective Payment System (IRFPPS). The IRFPPS final rule, published Aug. 7, 2001 in the Federal Register, established a prospective payment system for patients in facilities in which at least 75% of patients ... Bottom Line
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Bottom Line  |   February 01, 2002
PPS Takes Effect in Impatient Rehabilitation Facilities
Author Notes
  • Amy Hasselkus, is ASHA’s associate director for health services in speech-language pathology.
    Amy Hasselkus, is ASHA’s associate director for health services in speech-language pathology.×
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Healthcare Settings / Bottom Line
Bottom Line   |   February 01, 2002
PPS Takes Effect in Impatient Rehabilitation Facilities
The ASHA Leader, February 2002, Vol. 7, 1-13. doi:10.1044/leader.BML.07022002.1
The ASHA Leader, February 2002, Vol. 7, 1-13. doi:10.1044/leader.BML.07022002.1
On Jan. 1, an important change took effect at many rehabilitation facilities—the implementation of the Inpatient Rehabilitation Facility Prospective Payment System (IRFPPS). The IRFPPS final rule, published Aug. 7, 2001 in the Federal Register, established a prospective payment system for patients in facilities in which at least 75% of patients have received intensive rehabilitation services within the most recent 12-month reporting period. Patients typically require services for stroke, spinal cord injury, trauma, hip fracture, brain injury, congenital deformity, amputation, polyarthritis, neurological disorders, or burns. For some facilities, implementation will not occur until later this year, but the impact of this system will be felt for many years on speech-language pathologists.
The basis for payment under this PPS is the patient’s functional status rather than medical diagnosis. A patient’s functional status will be determined upon admission and discharge using the Patient Assessment Instrument (PAI), which consists of the following reporting areas: facility, admission, payer, and medical information, as well as medical needs, functional modifiers, and Functional Independence Measure (FIM) instrument.
The PAI score is used to assign patients to one of 21 Rehabilitation Impairment Categories (RICs), which reflect the primary cause of hospitalization based on ICD-9 codes. Within each RIC, a patient is assigned to a Case-Mix Group (CMG), which is based on functional status, age, and comorbidities. Payment is a flat rate based on the CMG and covers all Medicare Part A services during that episode of care. Payment is made upon discharge from the facility.
When using the PAI, you should be aware that:
  • Any clinician may complete the FIM items, although the Centers for Medicare and Medicaid Services (CMS) recognize that the assessment data would be most accurate if collected by a clinician with specialized training in the area to be assessed.

  • The average time to complete the FIM is 23 minutes, according to CMS.

  • Admission assessments must be completed on the fourth day of admission and encoded by day 10.

  • Discharge assessments are referenced from the day that the patient is discharged from the facility or when Medicare Part A benefits end, and must be completed by day 5 after discharge.

  • Discharge assessments must be encoded by the seventh calendar day after the PAI completion date (day 1 = the day the PAI is completed).

  • Assessment data from admission and discharge are submitted together by the seventh calendar day after the PAI “encode by” date (day 1 = the day the PAI is encoded).

  • An interrupted stay occurs when a patient is discharged from an IRF and returns to the same facility within three consecutive calendar days

Complete details about admission and discharge dates and transmission requirements can be obtained from CMS at http://www.cms.hhs.gov/InpatientRehabFacPPS/ or from the IRFPPS coordinator within a facility.
Advocacy Efforts
ASHA has provided written comments to CMS and met with the agency to express concerns regarding the use of the FIM on the PAI. At this time, swallowing disorders are considered a comorbidity on the scale, but not a specific FIM item (although it is combined with the eating item). There is no increased payment for a swallowing comorbidity unless the primary diagnosis is something other than a stroke. However, stroke is the primary diagnosis for 25% of rehabilitation patients, and 75% of stroke patients will require dysphagia services during their stay.
Also, the three-point scale used for swallowing is not sensitive enough to reflect the patient’s need for services and further reimbursement. ASHA has requested that a seven-point scale be used on the PAI to more thoroughly assess swallowing. An example of such a scale, the Functional Communication Measure for swallowing used on ASHA’s National Outcomes Measurement System (NOMS), was provided to CMS.
ASHA is closely monitoring the impact of IRFPPS on the use and outcomes of speech-language pathology services using data collected through NOMS. To assist this effort by collecting NOMS data, contact Tobi Frymark through the Action Center at 800-498-2071, ext. 4330, or by email at tfrymark@asha.org. For more information about IRFPPS implementation, contact Mark Kander at ext. 4139 or by email at mkander@asha.org.
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FROM THIS ISSUE
February 2002
Volume 7, Issue 2