CMS Releases Final Rules for Medicare Post-acute Care Services in FY 2021

Posted on August 05, 2020

The Centers for Medicare & Medicaid Services (CMS) made minor changes in the recently released final rules to update the Medicare fee-for-service inpatient psychiatric facility (IPF), inpatient rehabilitation facility (IRF) and skilled nursing facility (SNF) prospective payment systems for fiscal year (FY) 2021. The CMS made minimal changes in the rules for 2021, recognizing that resources are dedicated to the current health pandemic. Each of the rules takes effect Oct. 1.

Key provisions of the IPF final rule include:

  • A net 2.1% rate increase in the federal per diem base rate, increasing it from $798.55 to $815.22. The electroconvulsive therapy payment per treatment will also increase by 2.1% from $343.79 to $350.97.
  • A slight increase in the labor-related share from 76.9% to 77.3% based on the revised marketbasket.
  • A 5% cap on any wage index decreases, which ensures that each facility’s wage index is at least 95% of its current wage index.
  • Removal of “independent” from “licensed independent practitioner(s),” which will allow advanced practice providers such as physician assistants, nurse practitioners, psychologists and clinical nurse specialists the authority to practice at the top of their licenses, including the authority to record progress notes for patients.
  • Retention of the existing facility and patient-level adjustments for qualifying emergency departments, teaching programs, rural locations and use of the Medicare-Severity Diagnosis-related Group adjustment factor, with additional adjustments for patient comorbidities, age and length of stay.

In the IRF final rule, the CMS finalized a net rate increase of 2.2%, increasing the federal base rate from $16,489 to $16,856.  As proposed, the CMS finalized the permanent removal of the post-admission physician evaluation requirement that was temporarily eliminated due to the public health emergency; the removal of this requirement will reduce the unnecessary burden on IRF providers and physicians beginning in FY 2021.

The CMS also finalized a change in the IRF final rule allowing a nonphysician practitioner to perform one of the three required visits in lieu of the physician beginning the second week of patient care, when consistent with the practitioner’s scope of practice. The CMS made no changes to the IRF quality reporting program.

In the SNF final rule, the CMS finalized a net rate increase of 2.1% compared to FY 2020. The CMS made no changes to the redesigned SNF payment model known as the Patient Driven Payment Model (PDPM) implemented in FY 2020; instead, it is maintaining the current model weights and budget-neutrality adjustment. The CMS will continue to monitor provider behavior under the PDPM, including the impact of COVID-19, as well as patient outcomes and aggregate SNF prospective payment system payments. The agency also notes that it may consider future PDPM-related behavioral offsets. The final rule includes only nominal updates to the SNF value-based purchasing program.

In the next few weeks, the MHA will provide facilities with updated impact analyses of each of the final rules. Members with questions should contact Vickie Kunz at the MHA.

Tags: Medicare, CMS, IPF, SNF, IRF, Vickie Kunz

Posted in: Member News

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