New inpatient rehab PPS not compatible with UB-92

Rehab industry group requests CMS changes

The new prospective payment system (PPS) for inpatient rehabilitation facilities has begun to cause coders a number of problems related to how the PPS assessment instrument differs in language from the UB-92 coding guidelines.

The American Medical Rehabilitation Providers Association (AMRPA) of Washington, DC, has requested that the Centers for Medicare and Medicaid Services (CMS) change the inpatient rehabilitation facilities patient assessment instrument (IRF-PAI) and the UB-92 to ensure that the two forms better match.

"If the codes in the two forms matched, or in the very least cross-walked, providers would be able to develop electronic links so that the codes entered into one system would drop into the other," writes AMRPA in an April 24, 2002, letter to CMS.

Some of the UB-92 codes do not even have an equivalent on the IRF-PAI, indicating that the coding instrument is outdated. For example, the UB-92 code 61 reads: "Discharged to Medicare approved swing beds." There is nothing comparable on the IRF-PAI.

Also, the UB-92 code 05 for "discharged to another facility" could apply to any number of IRF-PAI codes, and the UB-92 code 71 for "discharged to another institution for outpatient services" could be the IRF-PAI 01 code for home, but this assessment item does not contain sufficient detail for a coder to make that translation.

These problems have presented unnecessary challenges to providers, and they require HIM professionals to painstakingly audit procedures to make certain the codes on the IRF-PAI correspond to the UB-92, according to AMRPA’s complaints to CMS.

In a recent letter responding to AMRPA’s concerns, CMS writes, "We are aware of the issues surrounding potential duplication and overlap with the UB-92. This is an issue that touches all of our payment systems. However, CMS considers it to be premature to make modifications to the instrument."

CMS continues, "Potential of collection processes is only one of the issues that must be considered in instrument revision. We have been using this instrument to implement the PPS for a very short time, i.e., implementation began on 1/1/02. Data regarding the completion of the instrument, as well as analysis of the data to assess the implementation, is not currently available."