August 30, 2018

Earlier this summer, your Academy made physiatry's voice heard with dedicated efforts to solicit member feedback and submit comments regarding the Centers for Medicare and Medicaid Services (CMS) FY 2019 Inpatient Rehabilitation Facilities (IRF), Skilled Nursing Facilities (SNF), and Hospital Inpatient Prospective Payment System (IPPS) proposed rules. The Fiscal Year 2019 final rules for IRF, SNF, and IPPS have now been released.

What do these final rules mean for physiatrists?

You can view a full summary of the impact of these rules on physiatry here. Some important items to note:

• Proposed Removal of the FIM™ Instrument and Associated Function Modifiers From the IRF–PAI Beginning with FY 2020 and Proposed Refinements to the Case-Mix Classification System Beginning with FY 2020: Your Academy expressed that this removal might result in another set of data being used in place of FIM™, which is heavily relied upon by rehabilitation physicians. Despite noting many objections from the provider community, CMS is finalizing its proposal to remove the FIM™ instrument and associated Function Modifiers from the IRF-PAI beginning in FY 2020, that is for all discharges occurring on or after October 1, 2019.
• ACADEMY WIN: Proposed Revisions to Therapy Provision Policies Under the SNF PPS: CMS proposed to limit group and concurrent therapy under the new PDPM. Your Academy supported the recommendation to encourage individualized care for patients in the SNF and supported the recommended 25 percent limit on group and concurrent therapy. CMS responded by approving the rule as proposed.
• ACADEMY WIN: Clinical Episode-Based Payment Measures: Your Academy explained that removing 6 measures from the IQR Program could result in reverting back to the MSPB measure, which would be too broad of a measure to tie to specific existing quality metrics and wouldn’t be meaningful to clinicians. In response, CMS did not remove the 6 measures.

Your Academy will continue to make physiatry's voice heard by taking every possible measure to provide feedback to CMS in regards to proposed changes. Stay tuned to www.aapmr.org for more updates on AAPM&R's ongoing advocacy efforts.