March 2001

News

PPS Postponement Buys Time for Providers

With a new administration in Washington, DC, and an extended comment period on its drafted rule, the Health Care Financing Administration (HCFA) will not likely implement the rehabilitation inpatient prospective payment system (PPS) by its April 1 deadline.

By mid-February, HCFA had not published a final rule of its November 3, 2000, draft published in the Federal Register. After publishing the final rule, which will take into account the comments received by February 1, HCFA must allow 60 days for those affected to prepare. With the Bush administration’s 60-day stay on all regulations, it seems unlikely that PPS will begin until fall, according to Barbara Marone, senior associate director of policy, American Hospital Association (AHA), Washington, DC.

This buys time for organizations like AHA to continue arguing for changes. Under PPS, HCFA asks all rehabilitation providers to use the Minimum Data Set for Post Acute Care (MDS-PAC) data collection system, a move that could prove time-consuming. “Preparing [for] MDS-PAC is a formidable job,” Marone says. “There is a huge learning curve.”

Most rehab professionals use the functional independence measure (FIM) assessment tool, a private sector system that has a scoring scale opposite to that of MDS-PAC. HCFA is downplaying the potential complications of the scoring discrepancies, Marone says. She adds that those who use FIM will have a better idea of which categories their patients fall into than those who do not use FIM. With MDS-PAC, she anticipates that rehab professionals will spend approximately 6 hours on data collection for each patient per average length of stay.

Marone expects that the Medicare Payment Advisory Commission (MedPAC) will suggest using the FIM system in its annual report, scheduled for release on March 1. “The field will be working very hard to see that HCFA heeds MedPAC’s recommendation,” she says.

If HCFA accepts the FIM system, it will have to make adjustments on the government end. Because FIM is a private sector product, HCFA will have to decide how to implement the system on a government level and distribute it through its Web site, a course of action HCFA will want to avoid because it will create more short-term work for the agency, Marone says.

AHA also has other concerns, including projected low reimbursements for medically complex patients and disproportionate share payments. Still, Marone says that the delay gives HCFA time to fine-tune the system with the advisories it received during the comment period.

Even then, it might not pass easily through the Bush administration. “The Office of Management and Budget has to approve that the benefits [of MDS-PAC] outweigh the cost,” Marone says. “The new administration is not just going to rubber stamp this. They are going to go over it carefully.”

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