Posted on June 27, 2017
The MHA submitted comments June 26 to the Centers for Medicare & Medicaid Services (CMS) regarding the fiscal year (FY) 2018 Medicare fee-for-service proposed rules to update the inpatient rehabilitation facility (IRF) and skilled nursing facility (SNF) prospective payment systems.
The MHA’s comments focused on changes to the quality reporting programs for both IRFs and SNFs, including opposition to the proposed adoption of the Changes in Skin Integrity measure that would replace the current Percent of Residents with Pressure Ulcers That Are New or Worsened measure. As proposed, the definition of pressure ulcers included in the measure is too subjective to collect reliable, accurate measure data across all facilities, which would result in the potential for a misleading portrayal of facility performance. The MHA encouraged the CMS to delay adoption of this measure until further testing is done.
The association also urged the CMS to delay implementation of standardized patient assessment data elements required by the Improving Medicare Post-acute Care Transformation Act of 2014 and to ensure implementation that minimizes the administrative burden on providers.
In addition, the MHA urged the CMS to ensure transparency by sharing a comprehensive policy rationale for the refinement of ICD-10-CM diagnostic codes that would count toward compliance with the IRF 60 percent rule. The MHA encouraged the CMS to release specific details annually for additions and deletions to the code list.
The CMS is expected to release final rules to update the IRF and SNF prospective payment systems by Aug. 1 for the Oct. 1 effective date. Members with questions should contact Vickie Kunz at the MHA.
Tags: Medicare, comments, inpatient rehabilitation facilities, IRF, SNF, skilled nursing facilities, proposed rule, 2018, pressure ulcers, skin integrity, ICD-10-CM, patient assessment
Posted in: Issues in Healthcare, Member News
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