CMS Releases FY 2021 IRF Proposed Rule

April 17, 2020
Rick Gawenda

On April 16, 2020, the Centers for Medicare and Medicaid Services (CMS) released the Fiscal year (FY) 2021 proposed rule for facilities under the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS). Highlights of the proposed rule include the following:

  • In the FY 2021 IRF PPS proposed rule, CMS is proposing to allow non-physician practitioners to perform any of the IRF coverage service and documentation duties that are currently required to be performed by a rehabilitation physician, provided that the duties are within the non-physician practitioner’s scope of practice under applicable state law
  • CMS is proposing to no longer require a post-admission physician evaluation since the post-admission evaluation covers much of the same information as continues to be included in the pre-admission screening of the patient and the patient’s plan of care
  • CMS is proposing an overall update of 2.9 percent (or $270 million) for FY 2021, relative to payments in FY 2020

The proposed rule will be published in the Federal Register on April 21, 2020. To access the proposed rule, click HERE.

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  1. New member question about co-treating. For Medicare Part A (acute care and IRF), when you are co-treating (for example, PT and OT treating at the same time working on different goals – for clinical indication not scheduling convenience), can each therapist bill their session in full or does the time need to be split (like it’s split for outpatient)? Thank you!

    1. IRF requires 3 hours of intensive therapy per day, 5 out of 7 days (there are exceptions). Having a PT and OT treat a Medicare IRF patient from 9-10 and count that as 2 hours would not be good in my opinion.

      1. Agree. Although this may not impact billing with bundles, are you aware of any regulation that states time should be split in the acute care setting? Seems to me that there isn’t much written about acute care and organizations use a variety of other regulations (like Medicare Part B) to fill in the gaps. Anyway, curious if you know of anything written about the acute care setting and co-treating. Thanks!

        1. Due to payment in the acute care setting (DRG’s), you are not paid via CPT codes so this is not addressed by CMS. The bigger concern is if that Medicare beneficiary switches from an inpatient to an outpatient and now therapy is being billed separately under Medicare Part B. This means all of the Part B documentation, coding and billing rules now apply. The vast majority of hospitals follow Medicare Part B billing guidelines with their Part inpatients. If you only received 30 minutes of therapy, would you want to be billed for 60 minutes of therapy assuming a PT and OT co-treated for the 30 minutes?