The Patient-Driven Payment Model took effect in October of 2019. Along with this change came the optional IPA. We are now five years into this change and questions still arise on when to complete an IPA. The decision of when to complete lies with the team at the facility. This team is not prescribed but identified by facility. The key question: does the 5-day PPS MDS completed on admission capture the current clinical picture being reimbursed (PDPM classification) or is an updated assessment warranted?
IPA Reminders
An IPA cannot be completed before the PPS 5-day Assessment.
Although the IPA is optional, there are several things to think about:
-
- It is considered an unscheduled assessment.
- It is deemed to be needed by the IDT per facility practice.
- It can be completed to capture clinical changes in the resident’s status and condition.
- It must be completed within 14 days after the ARD (ARD + 14).
The IPA is a stand-alone assessment. Thus, it should not be combined with other assessments.
The payment will change beginning on the Assessment Reference Date (ARD) and continues throughout the resident’s part A stay unless another IPA is completed or the resident is discharged. The Variable Per Diem (VBP) will not be affected by completion of the IPA.
“The IPA does not affect the variable per diem. When an IPA is completed and payment changes, it continues the variable per diem schedule that was established by the 5-day assessment.”
Is an IPA Needed?
When deciding to complete an IPA, comparison is to another PPS assessment (i.e., a 5-day or another IPA). Items to consider:
-
- Clinical category – is it still the reason for the skilled stay? Is the primary diagnosis still triggering the initial clinical category or has there been a change?
- Has the resident experienced any clinical changes? (For example, an infection requiring isolation or quarantine.)
- Is the resident receiving a new skilling service or need – such as IV medications or IV fluids for hydration?
- Has the resident’s cognitive status changed and/or declined since the prior assessment?
- Is the resident experiencing any swallowing issues?
- Consider changes in functional score and the corresponding impact.
-
- The IPA will reflect GG items for PT, OT, and the Nursing Component. A new column 5 is noted for section GG to capture the performance of the resident.
-
While this is not an all-inclusive list, this should help when starting to think about whether to IPA or not.
Tips for Tracking IPA Decisions
Generally, an interdisciplinary meeting happens throughout the stay of a Med A resident. Sometimes, this is called a “Triple Check” and/or “Medicare” meeting. These meetings can greatly assist in tracking whether it’s time to do an IPA.
-
- Do you have a team member(s) well versed in what an IPA is? If so, do they know they can trigger an IPA to be completed? If not, do you need to invest in training a team member(s) in identifying when an IPA is appropriate?
- Have you set up a way to track the decision-making process related to IPA? When an external reviewer comes in and questions whether an IPA should have been completed, will anyone remember the reason(s)? A safer approach would be to document those reasons in the minutes/notes of the interdisciplinary meeting surrounding the Med A resident being discussed.
- Develop a systematic approach to review the key areas that could affect whether an IPA might be warranted.
- Plan to review on a routine basis at your facility’s QAPI/QAA meeting.