IRF Countdown to Big Change Continues

Changes are effective Oct. 1, 2019

In this article, we aim to continue to remind Inpatient Rehabilitation Facilities (IRFs) of the looming transition from utilizing Functional Independence Measures (FIM^tm) for the purposes of assigning patients to a case-mix group (CMG) to the use of key quality indictor data – specifically the GG Self-Care and Mobility codes – for CMG placement and Medicare fee-for-service payment for IRF admissions. 

As Oct. 1, 2019, rapidly approaches, IRFs need to be in the final stages of training and preparation. Patients who are discharged on or after Oct. 1, 2019, will be paid based on the new formula.

Changes in the Final Rule
Related to this topic, the final rule for the 2020 fiscal year was published in the Federal Register on Aug. 8, 2019. The final rule closely matched the proposed rule, but it is noteworthy that several provisions were not finalized, including the weighting of the motor score for CMG placement and the requirement to submit quality indicator data for all patients regardless of the payor. CMS noted that delaying the weighting of the scores would provide IRFs with an easier transition under the revised formulas, but for IRFs that have calculated payment impact under the proposed formula, there is a need to take a second look.

Final Steps in Preparation
Because the changes impact patients discharged on or after Oct. 1, IRFs need to be ready by mid-September to ensure that data collected for patients with an average length of stay of approximately 13 days is accurate and complete. 

Again, while we’ve been collecting the data for several years, IRFs have focused on the accuracy of other data elements, and we have found in working with clients that they are facing challenges with scoring these elements and providing detailed documentation – not just a number – to support the scores.

Determine the Updated Impact
Along with the final rule for 2020, CMS posted updated rate-setting files.  IRFs can download the July 31, 2019, updated files at this link: Data Files. The rate-setting file will allow IRFs to calculate impact based on the updated formula, which does not weight the GG Functional Quality Indicators.

Finalize Documentation Changes
IRFs should be trialing any changes to their EMRs or paper templates now to ensure that workflow is efficient and that the correct scores and documentation to support them are present. 

Train, Train, Train
For staff who have utilized FIM^tm measures for many years, the switch in language and scoring may be difficult – old habits are hard to break, and this could significantly impact scoring accuracy and thus payment. Changing language to match the scoring definitions is essential in breaking the cycle.

Train, Audit, and Retrain
Review of scoring in “live” records will allow IRFs to identify and support training needs. This cycle should continue well past implementation.

What’s the Bottom Line?
The clock keeps ticking! We’re down to just six weeks before the transition, and should be finalizing training and form implementation now.