<h3>Research Objectives</h3> For nearly 20 years CMS required Inpatient rehabilitation facilities (IRF) providing care to Medicare beneficiaries to complete the IRF-PAI on patients for reimbursement of services which include the FIM instrument for the assessment of patient function and outcomes. In Oct 2016 CMS changed the IRF-PAI tool to include CMS-derived GG items which also assessed patient functioning, however, the items were not required for reimbursement. In Oct 2019 CMS required submission of GG items for medical reimbursement. The purpose of this study was to examine the implications of the changes that have transpired over the past five years. The objective is to compare Reliability and Consistency between the items of the FIM and the new CMS Section GG Functional Abilities items included in the IRF-PAI instrument from Fiscal Year 2017 to 2020. <h3>Design</h3> A retrospective cohort study using data from the Uniform Data System for Medical Rehabilitation (UDSMR): cases discharged in the Fiscal Year 2017 - 2020. <h3>Setting</h3> IRFs located in the US subscribing to UDSMR; roughly 85% of all IRFs in the nation subscribe to UDSMR for benchmarking reporting. <h3>Participants</h3> All Medicare cases for patients admitted in IRFs which are subscribers of UDSMR from the fiscal year 2016 to 2020 <h3>Interventions</h3> Not applicable. <h3>Main Outcome Measures</h3> Rehabilitation-related outcomes were compared; included were: average admission FIM® and average discharge FIM®, 16 GG self-care and mobility items plus bladder and bowel at admission and discharge which are included on CMS IRF-PAI instrument, Impairment conditions, CMG, LOS, discharge location. <h3>Results</h3> Forthcoming; patient outcomes as measured by the FIM and CMS GG items will be provided and trends examined over time The completion rates for items at admission and discharge by year will be analyzed including the reliability and validity of the items. Results may have policy implications in addition to possible impacts at the facility and patient level. <h3>Conclusions</h3> Presently the use of the following codes: -, ^, 7, 8, 9, 10, and 88 at admission or discharge is re-coded to a value of 1 for all GG functional items (except toilet transfer where a value of 2 is assigned) for reporting purposes per CMS. A value of 1 indicates the lowest level of function, in essence complete dependence, patient is unable to perform activity. CMS should reconsider assigning the value of 1 to patients with a code indicating the activity was not performed, as it is ultimately missing data and our analysis indicated the value of 1 may not be the most appropriate considering the discharge destination and the patient total length of stay in medical rehabilitation. Use of codes: -, ^, 7, 9, 10, 88 are missing values, where the patient's true level of functioning is unknown. This leads to uncertainty in the patient's true ability self-care and uncertainty regarding the most appropriate discharge setting to meet the patient's specific needs. Accuracy in assessment of patient's level of functioning is paramount in patient care and quality outcomes. CMS should consider removing the codes: -, ^, 7, 8, 9, 10 and 88 or advising clinicians to reserve use of the codes for the most atypical, rare exceptions. <h3>Author(s) Disclosures</h3> The authors declare that they have no relevant or material financial interests that relate to the research described in this poster
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