4.0 Policy
4.1 Statutory
Background
Under
Title 10, United States Code (USC), Section 1079(i)(2), the amount
to be paid to hospitals, Skilled Nursing Facilities (SNFs), and
other institutional providers under the TRICARE program, “shall
be determined to the extent practicable in accordance with the same
reimbursement rules as apply to payments to providers of services
of the same type under Medicare.” Based on this statutory provision, DHA
has adopted Medicare’s Prospective Payment System (PPS) for reimbursement
of IRFs currently in effect for the Medicare program as required
under Section 4421 of the Balanced Budget Act (BBA) of 1997 (Public
Law (PL) 105-33) by creating Section 1886(j) of the Social Security
Act (the Act). Section 1886(j) of the Act authorized the implementation
of a per-discharge PPS for IRFs. The IRF PPS payment for each patient
is based on information found in the IRF-Patient Assessment Instrument
(PAI). The IRF-PAI contains patient clinical, demographic and other
information about the patient, which classifies the patient into
distinct groups based on clinical characteristic and expected resource
needs. Separate payments are calculated for each group, including
the application of case and facility-level adjustments.
4.2 Applicability And Scope Of
Coverage
All IRFs
that meet the classification criteria for payment under the IRF
PPS under Title 42 CFR Part 412, subpart B, are considered authorized
IRFs under the TRICARE program.
4.3 Payment
On A Per Discharge Basis.
Under the PPS, IRFs receive
a pre-determined amount per discharge for inpatient services furnished
to TRICARE beneficiaries.
4.3.1 Payment
in full. The payment made under the IRF PPS represents payment in
full (subject to applicable deductibles, cost-shares, and copayments)
for inpatient operating and capital-related costs associated with
furnishing TRICARE covered services in an IRF, but not for the cost
of direct graduate medical education.
4.3.2 In addition
to payments based on prospective payment rates, IRFs receive payments
for the following:
4.3.2.1 Bad debt expenses, as provided
in 42 CFR 412.622(b)(2)(i).
4.3.2.2 A payment amount per unit for
blood clotting factor provided to TRICARE inpatients who have hemophilia.
4.4 Elements of the TRICARE IRF
PPS
4.4.1 Rates
4.4.1.1 As required by the Act, the
Federal rates reflect all costs of furnishing IRF services (routine, ancillary,
and capital related) other than costs associated with operating
approved education activities as defined in 42 CFR Parts 413.75
and 413.85, bad debts, and other costs not covered under the PPS. Federal
rates are adjusted to reflect:
4.4.1.1.1 Patient case-mix, which is
the relative resource intensity typically associated with each patient’s
clinical condition as identified through the patient assessment
process:
4.4.1.1.1.1 Cases are grouped into Rehabilitation
Impairment Categories, according to the primary condition for which
the patient was admitted to the IRF.
4.4.1.1.1.2 Cases are further grouped into
case-mix groups (CMGs), which group similar cases according to their
functional motor and cognitive scores and age.
4.4.1.1.1.3 Finally, cases are grouped
into one of four tiers within each CMG, according to patients’ comorbidities
(conditions that are secondary to the principal diagnosis or reason
for the inpatient stay). Each tier adds a successively higher payment
amount to the case depending on whether the costs of the comorbidity
are significantly higher than other cases in the same CMG (low,
medium, or high).
4.4.1.1.1.4 Additional adjustments are
made for interrupted stays, short stays of less than three days,
short stay transfers, and high-cost outlier cases.
4.4.1.1.2 Facility Level Adjustment Factors:
4.4.1.1.2.1 Rates are adjusted to reflect
geographic differences in wage rates, using the hospital wage index.
4.4.1.1.2.2 Rates are further adjusted
to account for a facility’s proportion of low-income patients, teaching
status, and rural area location.
4.4.1.2 Federal rates are updated annually:
4.4.1.2.1 To reflect inflation in the
cost of goods and services used to produce IRF services using a
market basket index calculated for freestanding and hospital-based
IRFs.
4.4.1.2.2 To reflect changes in local
wage rates, using the hospital wage index.
4.4.2 Classification Criterion
4.4.2.1 To be excluded from the TRICARE
Diagnosis Related Group (DRG)-based payment system and instead be
paid under the IRF PPS, an inpatient rehabilitation hospital or
rehabilitation unit of an acute care hospital (or CAH) must meet
the requirements for classification as an IRF stipulated in Subpart
B of 42 CFR Part 412.
4.4.2.2 One criterion specified at
42 CFR 412.29(b) that Medicare uses for classifying a hospital or unit
of a hospital as an IRF is that a minimum percentage of a facility’s
total inpatient population must require treatment in an IRF for
one or more of 13 medical conditions listed in 42 CFR 412.20(b)(2).
This minimum percentage is known as the compliance threshold, or
the 60% rule. DHA is adopting Medicare’s 60% requirement for IRFs.
4.4.3 Patient Assessments
4.4.3.1 Admission Orders
At
the time that each patient is admitted, the IRF shall have physician
orders for the patient’s care during the time the patient is hospitalized.
4.4.3.2 PAI
Payment for services is contingent
on the requirement that IRFs complete a PAI upon admission and discharge.
IRFs shall use the CMS IRF-PAI as specified in 42 CFR 412.606 that
covers a time period that is in accordance with the assessment schedule
in 42 CFR 412.610.
4.4.3.3 Comprehensive
Assessments
A
clinician of the IRF shall perform a comprehensive, accurate, standardized,
and reproducible assessment of each TRICARE inpatient as specified
in 42 CFR 412.606(c).
4.4.3.4 Coordination
of the Collection of Patient Assessment Data
A clinician of an IRF who has
participated in performing the patient assessment shall accept responsibility
for the data as specified in 42 CFR 412.612.
4.4.3.5 Transmission of Patient Assessment
Data
The
IRF shall encode, i.e., enter data items into the fields of the
computerized patient assessment software program, and transmit the
patient assessment data for each inpatient based on the data requirements
in 42 CFR 412.614. The IRF shall transmit the patient assessment
data:
4.4.3.5.1 Using the computerized version
of the PAI available from CMS; or
4.4.3.5.2 Using a computer program(s)
that conforms to CMS’ standard electronic record layout, data specifications,
and data dictionary, includes the required PAI data set, and meets
CMS’ other specifications.
4.4.3.6 Data
Collection Software
The Inpatient
Rehabilitation Validation and Entry System (jIRVEN) was developed
by CMS. jIRVEN is a free Java-based software application which provides
an option for IRFs to collect and maintain PAI information. Facilities
are able to enter and subsequently export their data from the application
for submission to the appropriate national data repository.
4.4.3.7 The IRF shall:
4.4.3.7.1 Electronically encode all required
data into a CMS approved IRF-PAI software product. This may include
jIRVEN, which is provided to IRFs for free on the CMS web site at
http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/Software.html.
jIRVEN provides an option for IRFs to collect and maintain IRF-PAI
information on any IRF patients. The jIRVEN software product allows
the IRF to enter data for each patient into the program and create
an electronic IRF-PAI for each patient. The IRF would import the
IRF-PAI data for the TRICARE patient into the jIRVEN system to produce
a report that includes a distinct five-character CMG number for
the patient which accounts for the existence of any relevant comorbidities.
The first character of the CMG number is an alphabetic character
that indicates the comorbidity tier. The last four characters of
the CMG number are numeric characters that represent the distinct
CMG number. The IRFs shall indicate this CMG reported for the TRICARE
patient IRF-PAI report on the TRICARE claim.
4.4.3.7.2 For TRICARE Medicare-eligible
patients, electronically transmit complete, accurate, and encoded
data from the PAI for each TRICARE patient to the national data
repository. An IRF may also attempt to electronically submit the
PAI to CMS data repository for non-Medicare-eligible TRICARE patients,
however, this data may or may not be accepted. Transmittal of the
TRICARE patient’s IRF-PAI does not affect TRICARE payment.
4.4.3.8 Once a TRICARE IRF patient
is discharged, the IRF submits a Healthcare Insurance Portability and
Accountability Act (HIPAA) compliant electronic claim, or a paper
claim (UB-04) using the five-character CMG number assigned by the
jIRVEN Grouper software when submitting claims for processing.
4.4.3.9 Assessment Process for Interrupted
Stays
The
IRF shall follow the assessment process for interrupted stays as
specified in 42 CFR 412.614.
4.4.4 Reasonable
and Necessary Criteria
In
order for an IRF claim to be considered reasonable and necessary,
there shall be a reasonable expectation that the patient meets all
of the requirements in 42 CFR 412.622(3)(i) through (iv) at the
time of the patient’s admission to the IRF.
4.4.4.1 Documentation.
To
document that each patient for whom the IRF seeks payment is reasonably
expected to meet all of the requirements in
paragraph 4.5.3 at the time
of admission, the patient’s medical record at the IRF shall contain
the documentation outlined in 42 CFR 412.622(4)(i) through (iii).
4.4.4.2 Interdisciplinary Team Approach
To Care
In order
for an IRF claim to be considered reasonable and necessary, the
patient must require an interdisciplinary team approach to care,
as evidenced by documentation in the patient’s medical record of
weekly interdisciplinary team meetings that meet the requirements
in 42 CFR 412.622 (A) through (C).
4.5 Basis of Payment
4.5.1 For admissions prior to October
1, 2018, IRFs shall be reimbursed based on billed charges or negotiated
rates.
4.5.2 For
admissions on or after October 1, 2018, inpatient services provided
in IRFs shall be reimbursed in accordance with Medicare’s IRF PPS
as found in Title 42 CFR, Part 412, Subpart P. IRF PPS payments
shall be made on the basis of prospectively determined rates and
applied on a per discharge basis.
4.5.3 To the extent practicable,
in accordance with 10 USC 1079(i)(2), DHA will adopt Medicare’s IRF
PPS methodology, to include Medicare’s relative weights, payment
rates, adjustments for the 60% compliance threshold, and high cost-outlier
payments.
4.5.4 DHA is adopting Medicare’s
IRF adjustments for interrupted stays, short stays of less than three
days, short-stay transfers, teaching adjustments, rural adjustments,
and the Low Income Payment (LIP) adjustment.
4.5.5 DHA is also adopting Medicare’s
IRF Quality Reporting Program (IRFQRP) payment adjustments for TRICARE-authorized
IRFs that reflect Medicare’s annual payment update for that facility.
DHA is not establishing a separate reporting requirement for IRFs,
but will utilize Medicare’s payment adjustments resulting from their
IRFQRP that are included in the IRF-PPS Pricer.
4.5.6 IRF PPS Pricer Software. CMS
has developed an IRF Pricer Program that calculates the IRF payment
rate for each case. The Pricer software uses the CMG number, along
with other specific claim data elements and provider-specific data,
to adjust the IRF’s prospective payment for interrupted stays, transfers,
short stays, and deaths, and then applies the applicable adjustments
to account for the IRF’s wage index, percentage of low-income patients,
rural location, outlier payments, and the teaching status adjustment.
4.6 QRP
DHA
will apply the same QRP reductions as Medicare.
4.7 Transition Period
In the Final Rule (FR) published
in the Federal Register on December 29, 2017, DHA created
a multi-year transition period to buffer the impact from any potential
decrease in revenue that rehabilitation facilities may experience
during the implementation of a revised IRF inpatient payment system.
This transition period provides IRFs with sufficient time to adjust
and budget for potential revenue reductions. The transition is as
follows:
4.7.1 For
the first 12 months following implementation, the TRICARE IRF PPS
allowable cost will be 135% of Medicare IRF PPS amounts.
4.7.2 For the second 12 months following
implementation, the TRICARE IRF PPS allowable cost will be 115%
of the Medicare IRF PPS amounts.
4.7.3 For
the third 12 months following implementation, and subsequent years,
the TRICARE IRF PPS allowable cost will be 100% of the Medicare
IRF PPS amounts.
4.8 General
Temporary Military Contingency Payment Adjustment (GTMCPA) Payments
4.8.1 The
Director, DHA, or designee, may approve a GTMCPA payment based on
all of the following criteria:
4.8.1.1 The IRF serves a disproportionate
share of Active Duty Service Members (ADSMs) and Active Duty Dependents
(ADDs), i.e., 10% or more of an IRF’s total inpatient admissions
are for ADSMs and ADDs.
4.8.1.2 The IRF is a TRICARE network
hospital.
4.8.1.3 The IRF’s actual costs for
TRICARE inpatient services exceed TRICARE payments for those services
or other extraordinary economic circumstance exists; and
4.8.1.4 Without
the GTMCPA payment, the Department of Defense’s (DoD’s) ability
to meet military contingency mission requirements will be significantly
compromised.
4.8.2 Following
is the GTMCPA Payment Process for TRICARE IRFs.
4.8.2.1 The
IRF shall submit a request for a discretionary GTMCPA payment to
their regional Managed Care Support Contractor (MCSC). The request
shall be made to the contractor within 12 months of the end of the
IRF year (October 1 through September 30) for which the IRF is requesting
a GTMCPA payment. For example, an IRF shall submit a request for
a GTMCPA payment for the IRF year ending September 30, 2019, by
September 30, 2020. Late submissions or requests for extensions
shall not be considered.
4.8.2.2 The
IRF shall submit the following information to the contractor for
review and consideration:
• Their IRF-specific Medicare
provider number.
• The
total number of IRF admissions (from all payers) during the 12-month
period in the previous TRICARE IRF year and the total number of
TRICARE ADSM and ADD admissions in this same period. An IRF shall
not include TRICARE Non-Active Duty Service Member (NADSM) or Non-Active
Duty Family Member (NADFM) admissions (i.e., TRICARE retiree or
TRICARE retiree dependents), TRICARE for Life (TFL) beneficiary
admissions, overseas beneficiary admissions, or TRICARE beneficiary
admissions with Other Health Insurance (OHI). TRICARE Uniformed
Services Family Health Plan (USFHP) ADSM and ADD IRF admissions
may be included in the IRF’s submission if the stays were paid utilizing
the IRF-PPS Reimbursement System, however, these admissions shall
be separately identified as TRICARE USFHP admissions by the IRF.
• The total billed and paid amounts
for all TRICARE IRF admissions paid by the IRF PPS at the IRF during
the 12-month period, excluding TRICARE OHI and TRICARE USFHP admissions.
This includes non-OHI claims for ADSMs, ADDs, and retirees and their dependents.
4.8.2.3 The
contractor shall perform a thorough evaluation of the IRF’s request
in
paragraph 4.8.2.2. The evaluation shall consist
of the following:
4.8.2.3.1 The contractor shall evaluate
the IRF’s package for completeness. The contractor shall verify
the IRF has provided all components in
paragraph 4.8.2.2.
4.8.2.3.2 The
contractor shall perform a validation that the IRF meets the disproportionate
share criteria (as stated in
paragraph 4.8.1). The contractor shall independently
calculate the number of TRICARE ADD/ADSM IRF admissions, utilizing
the contractor’s data systems, and divide it by the total number
of IRF admissions (from all payers) reported by the IRF in
paragraph 4.8.2.2.
The contractor shall compare this result to the IRF’s submission
in
paragraph 4.8.2.2 to ensure the hospital met
the disproportionate share criteria in
paragraph 4.8.1. The contractor
shall work with the IRF to resolve discrepancies in the reported
data prior to submission of the request to DHA if the IRF’s data
show that they qualify, but the contractor’s data show that they
do not.
4.8.2.3.3 The contractor shall perform
an evaluation to determine if the IRF is essential for continued
network adequacy and is necessary to support military contingency
mission requirements. The contractor shall report the following
data elements for the prior IRF year, i.e., the year prior to the requested
GTMCPA, as well as provide a brief narrative with supporting rationale,
describing why the IRF is essential for continued network adequacy
and why a GTMCPA payment is necessary to maintain this continued
network adequacy.
4.8.2.3.3.1 Number of IRFs and IRF beds
in the network locality;
4.8.2.3.3.2 Efforts that have been made
to create an adequate network;
4.8.2.3.3.3 Availability of IRF services
in the locations or nearby; and
4.8.2.3.3.4 Other cost effective alternatives
and other relevant factors.
4.8.2.3.4 If
the contractor’s independent analysis shows that: (1) the IRF met
the disproportionate share criteria; and (2) the IRF is essential
for continued network adequacy, the contractor shall submit all
documentation in
paragraphs 4.8.2.2 and
4.8.2.3.3 to
the Chief, MCSC Program. If the IRF fails to meet the disproportionate
share criteria or is not essential for continued network adequacy,
the contractor shall notify the Chief, MCSC Program of their findings,
but shall not submit the full request for a GTMCPA payment to the
Chief, MCSC Program unless requested by the Chief, MCSC Program.
4.8.3 The
Chief, MCSC Program will perform a thorough review and analysis
of the IRF’s submission and the contractor’s review, utilizing any
DHA data the Chief, MCSC Program deems necessary, to determine if
the IRF meets the four criteria listed in
paragraph 4.8.1 and qualifies
for a GTMCPA payment. If the IRF qualifies, the GTMCPA payment shall
be set by the contractor utilizing DHA and CMS data so that the
IRF’s Payment-to-Cost Ratio (PCR) for TRICARE IRF services does
not exceed a ratio of 1.15. The TRICARE IRF PCR shall be calculated
using the IRF’s Medicare Cost-To-Charge Ratio (CCR) in the most
recent version of the CMS IRF Provider Specific File (PSF). If a
freestanding TRICARE IRF does not have a Medicare IRF-specific CCR
in the PSF, the contractor shall calculate an average CCR based
on the Medicare IRF CCRs in the most recent PSF file, weighted by
total number of TRICARE cases in each IRF in the contractor’s region
during the relevant period. If a specialty IRF unit in an acute
care hospital does not have a Medicare IRF unit-specific CCR, then
the contractor shall use the Medicare CCR for the co-located acute
care hospital to determine the IRF’s TRICARE costs. An IRF shall
not be approved for a GTMCPA if the payment would result in the
IRF’s PCR exceeding 1.15. The Chief, MCSC Program will forward their
recommendation for approval of the GTMCPA payment and the recommended
percentage adjustment to the Director, DHA. Disapprovals by the
DTRO will not be forwarded to the Director, DHA, for review and
approval. The PCR shall be calculated as follows:
Step 1: Determine the IRF’s total TRICARE
payments in the 12-month period, excluding TRICARE OHI and USFHP
claims. The IRF GTMCPA payment is specific to the IRF PPS reimbursement
system and there is no authority to include non-IRF PPS paid amounts in
the PCR calculation.
Step 2: Determine the IRF’s estimated
TRICARE costs by identifying the TRICARE billed charges for all
non-OHI, non-USFHP TRICARE IRF admissions. The contractor shall
then multiply the IRF’s total TRICARE billed charges for these beneficiaries
during the 12-month period by the Medicare IRF-specific CCR (as
determined in
paragraph 4.8.3).
Step 3: Divide
Step 1 (total TRICARE non-OHI, non-USFHP IRF payments in the 12-month period)
by Step 2 (total TRICARE non-OHI, non-USFHP IRF estimated costs
in the 12-month period).
Step 4: If the amount in Step 3 is
lower than 1.15 the IRF may receive a GTMCPA payment so that the
IRF’s total TRICARE payments in the 12-month period are equal to
or less than 115% of their TRICARE costs in the same period. The
percentage used is at the discretion of the Director, DHA, or designee.
4.8.4 TRICARE
IRF payments (non-OHI, non-USFHP) for the qualifying IRF will be
increased by the Director, DHA, or designee, at his/her discretion
by way of an additional GTMCPA payment after the end of the TRICARE
IRF year (October 1 through September 30). Subsequent adjustments
to the GTMCPA payment will be issued to the qualifying IRF for the
prior IRF year, when requested by the IRF, to ensure claims that
were paid-to-completion the previous year are adjusted. These adjustments
are separate from the applicable GTMCPA payment approved for the
current IRF year.
4.8.5 Upon
approval of the GTMCPA payment request by the Director, DHA, or
designee, the Chief, MCSC Program will notify the Contracting Officer
(CO) who will send a letter to the contractor notifying them of
the GTMCPA payment approval.
4.8.6 The
contractor shall process the GTMCPA payments per the instructions
in Section G of their contracts under Invoice and Payment Non-Underwritten
- Non-TRICARE Encounter Data (TEDs), Demonstrations. No GTMCPA payments
shall be sent out without approval from DHA-Aurora (DHA-A), Contract
Resource Management (CRM), budget.
4.8.7 DHA
will send an approval to the contractors to issue GTMCPA payments
out of the non-financially underwritten bank account based on fund
availability.
4.8.8 GTMCPA
payments will be reviewed and approved on an annual basis; i.e.,
they will have to be evaluated on a yearly basis by the Chief, MCSC
Program in order to determine if the IRF continues to serve a disproportionate
share of ADSMs and ADDs and whether there are any other special circumstances
significantly affecting military contingency capabilities.
4.8.9 The Director, DHA, or designee
is the final approval authority for GTMCPA payments. A decision
by the Director, DHA, or designee to approve, reject, adopt, modify,
or extend GTMCPA payments is not subject to the appeal and hearing
procedures in
32 CFR 199.10.
4.8.10 DHA,
upon request, will provide the detailed IRF claims data and Medicare
CCR used to calculate the IRF’s PCR and maximum GTMCPA payment,
if any, to the requesting IRF through the contractor.
4.8.11 GTMCPAs
may be extended to IRF facilities that have changed their network
status during the IRF GTMCPA year. If an IRF network facility changes
their status during the IRF year, and the facility was and remained
a network facility that is essential for military readiness, contingency
operations, and network adequacy and the facility served a disproportionate
share of ADSMs and ADDs during the period of the year it was subject
to IRF reimbursement, then a prorated IRF GTMCPA may be authorized. Any
IRF adjustment will only apply to IRF payments.
4.9 Billing and Coding Requirements
4.9.1 Once an IRF patient is discharged,
the IRF shall submit a HIPAA compliant electronic claim, or a paper
claim (UB-04) using the five-character CMG number when submitting
claims for processing. In addition to all entries previously required
on a claim, the following additional instructions shall be followed
to accurately price and pay a claim under the IRF PPS.
4.9.2 The IRF shall bill using Bill
Type 11X along with Revenue Code 0024.
4.9.3 Contractors shall process the
claim using Type Of Institution 46 for IRFs.
4.9.4 The contractors shall use Pricing
Rate Code (PRC) CI for CAH IRF reimbursement and RF for all
other IRF reimbursement.
4.10 Direct Medical Education
DHA
will reimburse IRFs who file a request for their direct medical
education costs in a timely manner, as outlined in
Chapter 6, Section 8. Although the procedures
listed in
Chapter 6, Section 8 pertain to DRGs, those
same procedures are to be used to reimburse IRFs for direct medical
education costs.