Home Health & Hospice Week

Will examination lead to drop in IRF referrals?

Another home health-related topic has landed on the HHS Office of Inspector General’s scrutiny list.

The OIG has put “Early Discharges From Inpatient Rehabilitation Facilities to Home Health Services” on its Work Plan, and plans to issue a report on the topic next year.

“Under the inpatient rehabilitation facility (IRF) prospective payment system (PPS), the Centers for Medicare & Medicaid Services (CMS) established an IRF transfer payment policy based on a per diem amount for each case-mix group (CMG) for which the discharge occurred before the average length of stay for the respective CMG,” the OIG explains on its website. “The IRF transfer payment policy applies to early IRF transfers to another IRF, an inpatient hospital, a nursing home that accepts payments under Medicare or Medicaid, or a long-term-care facility.”

The policy mirrors similar early transfer proration policies for hospital DRGs, with one difference — the IRF transfer policy currently doesn’t apply when patients are discharged to home health or hospice, while the hospital transfer policy does.

“CMS excluded IRF discharges to home health services from this policy because the home health agency PPS had just been developed and claims data were not available for CMS to analyze,” the OIG says. “CMS was concerned, however, about IRF incentives to discharge patients prematurely under the IRF PPS to home health services.”

The OIG plans “to determine how an IRF transfer payment policy for early discharges to home health services would financially affect Medicare Part A and IRFs,” the agency says.

Translation: Expect to see home health added to the IRF transfer policy eventually, experts say. While the policy is technically one that applies only to IRFs, it will affect HHAs if rehab facilities curb referrals to home health due to the anticipated change.

Resource: See the Work Plan at https://oig.hhs.gov/reports-and-publications/workplan/index.asp.