The 2022 Inpatient Rehab Facility PPS Proposed Rule

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 2022. Here’s a quick run-down of the major changes in the proposed rule:

  • 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 percentage point multi-factor productivity (MFP) adjustment. This could change if more recent market basket data becomes available before the final rule is issued.
  • IRFs that do not meet reporting requirements are subject to a two-percentage point (2.0%) reduction in their Annual Increase Factor. There are new and updated measures outlined below.
  • A new proposed measure will require IRFs to report COVID-19 healthcare provider vaccinations in their facilities. This proposed measure is designed to assess whether IRFs are taking steps to limit the spread of COVID-19.
  • 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.
  • For the FY 2024 payment determination and subsequent years, CMS is proposing to add the Follow-up After Psychiatric Hospitalization (FAPH) measure to the IPFQR Program. This claims-based measure expands the cohort of the Follow-up After Hospitalization for Mental Illness (FUH) measure, which is currently in the IPFQR Program, to include patients with substance use disorders. It also expands the provider types who can provide follow-up care to include primary care providers. CMS is proposing to remove the FUH measure from the IPFQR Program if the FAPH measure is adopted.
  • In efforts to reduce provider burden, CMS is also proposing to remove three chart-abstracted measures from the IPFQR Program for the FY 2024 payment determination and subsequent years.  These measures are Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention, Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment, and Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or any Other Site of Care).
  • Additionally, CMS is proposing to transition to patient-level reporting for chart-abstracted measures beginning with voluntary reporting of data for the FY 2023 payment determination and transitioning to required patient-level reporting for the FY 2024 payment determination and subsequent years.

For more information, see the fact sheet from CMS, and check out the full proposed rule on the Federal Register (available to view/download 4/12/21).