In response to the Centers for Medicare and Medicaid Services’ (CMS) proposed rule regarding new potential updates to the payments and care delivery for Inpatient Rehabilitation Facilities (IRFs) beginning October 1, 2014, RehabCare submitted formal comments and reactions prior to the June 30 deadline.

On behalf of the five free-standing Inpatient Rehab Hospitals and 104 hospital-based Acute Rehab Units that RehabCare owns and operates or manages, we used the opportunity of the proposed rule to advocate for IRF-level care and those patients who benefit from such care.

Among other specific comments to several CMS proposed changes, RehabCare concluded that:

“Preserving patient access to essential rehabilitation services and maintaining IRF providers’ ability to furnish those services is critical to enabling patients to achieve a full recovery and return home. To achieve these goals, RehabCare recommends that CMS not preclude additional codes from being included in the “presumptive compliance” methodology and adopt a streamlined process to determine compliance with the 60% Rule. RehabCare also supports CMS’s “limited medical review” proposal but suggests that CMS align the time period for data collection on the IRF-PAI with the implementation of any arthritis coding changes and the beginning of “limited medical review” period to facilitate this process.

Additionally, RehabCare supports changes to the proposed therapy data collections requirements to limit the administrative burden and more accurately define the different therapy modalities. RehabCare recommends that CMS withdraw its consideration to establish a maximum threshold on the overall percentage of group therapy an IRF patient can receive until an appropriate analysis of the effect of the type of therapy on patient outcomes is available and that CMS transition to the new CBSAs over a two-year period.”

RehabCare is committed to advocating on behalf of those patients who rely on essential rehabilitation services and on behalf of the nation’s network of IRF providers. We appreciate opportunities, such as commenting on CMS’ proposed rule, to help influence the future of IRF care. We look forward to working with CMS, policy makers and the stakeholder community to ensure patients have continued and ready access to the best rehabilitative care necessary for their recovery.

Next Steps
Over the next several weeks, CMS staff will consider the formal comments submitted by a broad range of stakeholders as they prepare a final IRF payment rule. The final rule will be released on or around August 1 and will go into effect on October 1, 2015.

We will provide further updates after the final rule is issued to share CMS’ responses to stakeholder comments.
By RehabCare