GNYHA recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the fiscal year (FY) 2020 inpatient rehabilitation facility (IRF) prospective payment system (PPS) proposed rule. GNYHA addressed the proposed removal of the list of compliant IRFs from the IRF Quality Reporting Program (QRP) website, possible errors in the IRF wage index calculation, and the proposed data collection of social determinants of health (SDOH). The comment letter is attached.

Proposed Removal of the List of Compliant IRFs

GNYHA is concerned about CMS’s proposal to stop publishing a list of IRFs compliant with the IRF QRP on its website. While individual providers could still access their own compliance status, we believe that this information should be publicly available so that stakeholders like GNYHA could use the data to calculate payment impacts for members. We also recommended that lists of QRP-compliant facilities be posted in a standardized manner at a central location across the various PPS QRPs.

Issues with the IRF Wage Index Calculation

CMS proposed that the FY 2020 IRF wage index equal the FY 2020 pre-floor, pre-reclassified, unadjusted inpatient PPS (IPPS) wage index, which would align the years of data used for the IRF wage index with the IPPS and the outpatient PPS. GNYHA supported this proposal but noted that we could not match the published FY 2020 proposed IRF wage index values to the pre-floor, pre-reclassified wage index calculated in the FY 2020 IPPS proposed wage index public use file. CMS has since confirmed that both the IRF and inpatient psychiatric facility PPS wage index values contained errors that the final rule will correct. GNYHA will review the prior year calculations to ensure accuracy and will apprise members of any findings related to improper reimbursement.

Proposed Social Determinants of Health Data Collection

Finally, CMS proposed to collect SDOH data within the standardized patient assessment data elements (SPADEs), including data on race, ethnicity, preferred language, interpreter services, health literacy, transportation, and social isolation. While GNYHA supports this proposal, we recommended that CMS require data on race, ethnicity, preferred language, and interpreter services, and make data collection on health literacy, transportation, and social isolation voluntary to alleviate providers’ potential burden. GNYHA also recommended that CMS consider including the housing status collection in the future. Additionally, GNYHA encouraged CMS to ensure that SDOH data collected in the IRF PPS is aligned with proposed SDOH data collection in other post-acute care settings. GNYHA’s crosswalk of the SPADEs and quality reporting measures used across the various post-acute care settings is available here.