Different PAC sites use different measurement tools, which are introduced and defined below. These different assessment instruments have made it difficult to compare patient outcomes across the post-acute care continuum.
Inpatient Rehabilitation Facility: Functional Independence Measure
The Inpatient Rehab Facility’s Patient Assessment Instrument (IRF-PAI) removed the 18-item Functional Independence Measure™ (FIM™) Scale.[i] The change will apply on October 1, 2019.[ii] The FIM™ assessed the level of disability in motor and cognitive functioning to determine the burden of care for a patient’s caregivers. 13 of the 18 determined the motor score and five of the 18 determined the cognitive score.[iii]
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Table 3: This table matches the patient assessment tools used with the facility in which the are used.
Patient Assessment Tool
||PAI (Patient Assessment Instrument)
||MDS (Minimum Data Set)
||OAIS (Outcome and Assessment Information Set)
In addition to removing the FIM™, CMS finalized the incorporation of certain data from the Quality Indicators section of the IRF-PAI into the IRF case-mix classification system. These data items will be used to assign patients into a Case-Mix Group (CMG) for payment under the IRF PPS on or after October 1, 2019.[iv] CMS plans to provide training and educational resources on the data items in the Quality Indicators section of the IRF-PAI before this policy takes effect on October 1, 2019.[v]
Skilled Nursing Facility: Minimum Data Set
The Minimum Data Set (MDS) is the clinical assessment of SNF (or nursing home) residents,[vi] the purpose of which is to standardize patient assessment and facilitate care management.[vii] It is one of three components of the Resident Assessment Instrument (RAI), in combination with Care Area Assessment (CAA) Process, and the RAI Utilization Guide. These three components assess functional status, strengths, weaknesses, and guidance on further assessment once issues are identified.[viii]
The MDS 3.0 is federally mandated to assess the clinical conditions of SNF residents receiving Part A SNF care, under the SNF Prospective Payment System Rule (SNF PPS).[ix]
The MDS is currently on its most recent version, known as the MDS 3.0.[x] This version is believed to improve on MDS 2.0 in reliability, accuracy, standardization, and usefulness.[xi] The MDS 3.0 is a set of functional, clinical, and screening elements that combine to assess the acuteness of a patient’s condition.[xii] As of October 1, 2019, the MDS makes the Interim Payment Assessment (IPA) an optional assessment that providers will be able to determine their own criteria for when it is complete. Because the IPA is an optional assessment and providers can determine their own criteria for when an IPA is completed, CMS is revising the Assessment Reference Data (ARD) criteria such that the ARD will be the date the facility chooses to complete the IPA relative to the triggering event that causes the facility to choose to complete the IPA. Payment based on the IPA would begin the same day as the ARD.[xiii]
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Home Health: Outcome and Assessment Information Set
The Outcome and Assessment Information Set (OASIS) is the data set used in home health agencies seeking Medicare certification. OASIS compliance is a requirement of the Medicare Conditions of Participation. New HOME HEALTHs must show that the facility can transmit OASIS data prior to the initial certification survey.[xiv]
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Long Term Acute Care Hospitals
LTCHs are currently treated as an acute care hospital.
[xiii] U.S. Department of Health and Human Services, Centers for Medicare & Medicaid Services. Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNF) Final Rule for FY 2019, SNF Value-Based Purchasing Program, and SNF Quality Reporting Program. http://hhs.com/assets/docs/2018-16570.pdf. Published August 8, 2018. Accessed May 29, 2019.