Rehabilitation hospitals say a proposed change to how the CMS will reimburse them for care could lead to inaccurate payments as new system pulls patient data from a new source.
In the 2019 inpatient rehabilitation proposed pay rule, the CMS proposed to retire the current patient assessment tool that helps categorize the level of care needed by a patient. The CMS used the information since 2002 to help determine IRF's care reimbursement. But now the agency wants to switch to a new patient assessment tool that's similar to one in place for other post-acute care settings to create a more uniform evaluation for patients' care needs. The change will kick in on Oct. 1, 2019 if it's finalized.
Clinicians use the tool in question to rank the severity of the patients care needs and develop a treatment plan.
The new assessment tool was introduced last year and it's unclear if it tracks patient needs sensitively enough to determine reimbursement accurately. "The limited analysis CMS has made available to stakeholders is insufficient evidence as to the data's validity or reliability as a basis for payment purposes," Richard Kathrins, chair of American Medical Rehabilitation Providers Association's board of directors, said in a comment letter.
Providers are worried about whether the new tool asks the right questions and helps them evaulate patients as thoroughly as the assessment method they've been using for years. The tool is still too new to answer those questions, according to rehab providers.
"Too little is known about the accuracy, consistency and clinical efficacy of the new clinical data and information that CMS is proposing to utilize," Mark Tarr, president and CEO of Encompass Health, one of the largest providers of rehab hospital services in the nation said in a comment letter. "These clinical data and information have not been sufficiently studied, understood or validated to determine payment or patient care implications for rehabilitation hospital services."
The Kentucky Hospital Association suggested the CMS should study and evaluate the accuracy and reliability of the new data source as well as its implications before changing the reimbursement model.
Jane Snecinski, president of consultancy Post-Acute Advisors, said these providers have a valid reason to be concerned.
"The dangers of moving from a validated system to one that doesn't have that history may put providers at risk," Snecinski said. "With limited validation and no piloting of a new system, how can the risk be evaluated?"
