Acknowledging that the COVID-19 pandemic should be the focus of attention, CMS released a proposed rule that makes no changes to quality reporting.
CMS fact sheet

The big picture: A 2.9% increase and continued efforts to lessen administrative burden.
In light of rapid changes being made to Medicare in response to the COVID-19 pandemic, the U.S. Centers for Medicare & Medicaid Services issued a pared-down proposed rule for inpatient rehabilitation facilities that sticks to the basics — including a 2.9% payment increase and the elimination of physician evaluations within the first 24 hours of patient admission. The 2.9% increase represents an estimated increase of about $270 million in payments to IRFs. 

In a fact sheet on the proposed rule, CMS writes that it’s meeting a statutory obligation to update Medicare payment policies annually, but the COVID-19 pandemic demands widespread attention and “CMS has limited annual IRF rulemaking required by statute to essential policies.” 

The final rule would go into effect on October 1, 2020. APTA will provide comments on the proposed rule before the June 15, 2020, deadline.

Also notable in the proposed rule:

• No changes to quality reporting. For the first time in years, CMS will leave IRF quality reporting measures untouched from what was set in place in the previous year.
• Changes to the geographic wage index, and a limit on decreases. The proposed rule adopts geographic delineations proposed by the Office of Management and Budget to determine whether a provider is considered a rural or urban facility — a key element in determining the IRF wage index. CMS hopes to accompany that change with a 5% limit in FY 2021 in any decrease in a facility’s wage index compared with its wage index for the prior fiscal year to help providers adapt to the revised OMB delineations. 
• Non-physician providers allowed to perform coverage service and documentation. CMS is proposing that non-physician practitioners — typically defined by the agency as physician assistants, nurse practitioners, and clinical nurse specialists — be permitted to perform duties currently reserved for physicians, as long as those duties are within the practitioner’s scope of practice established in state law. 
• Flexibility around physician evaluations. Although the proposed rule would lift the requirement for a physician evaluation within the first 24 hours of admission, IRFs would still have the ability to conduct a visit in that timeframe if conditions warrant. 
• Another call for comments on reducing administrative burden. CMS accompanies almost every proposed rule with an invitation for comment on changes that could be made to reduce unnecessary paperwork and other administrative burdens — an invitation that APTA takes up at every opportunity.