fah hospital policy blog

Perspectives on health policy affecting America’s hospitals and the patients we serve.

FAH Comments on FY2019 IRF and IPF Proposed Payment Rules

June 27, 2018 | FAH Policy Blog team

Category: HIT, Quality

Today, the Federation of American Hospitals (FAH) submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the FY 2019 Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) proposed rule and the FY 2019 Inpatient Psychiatric Facilities (IPF) PPS proposed rule. 

IRF Proposed Rule

The FAH's comments on the IRF PPS proposed rule were highlighted by responses to CMS's proposal to remove the FIM™ Instrument from the IRF-PAI and undertake refinements to the Case-Mix Classification System in FY 2020. The FAH opposed CMS’s proposal due to data quality issues and lack of clinical validation and transparency in the process of refining the Case-Mix Classification System. These changes would introduce instability into the IRF payment system and could threaten access to IRF care for patients. The FAH recommended that CMS not move forward with the proposed changes in FY 2020 and instead examine and address the data quality issues reported. The FAH also recommended that CMS work with the provider community to ensure common understanding of the clinical measurement approach and solicit and address any concerns regarding the proposed system.

In addition, the FAH also provided comments in response to proposals affecting coverage requirements, high-cost outliers, wage adjustment, and the IRF Quality Reporting Program, as well as in response to CMS’s Request for Information on Promoting Interoperability and Electronic Healthcare Information Exchange. The FAH’s full comment letter can be viewed here.

IPF Proposed Rule

The FAH’s comments on the IPF PPS proposed rule were highlighted by responses to CMS’s proposals regarding wage index adjustments, IPF cost reporting, the IPF Quality Reporting Program, as well as in response to CMS’s Request for Information on Promoting Interoperability and Electronic Healthcare Information Exchange. The FAH’s full comment letter can be viewed here.