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By Remy Kerr, MPH, AMRPA Health Policy and Research Manager Earlier this month, the Centers for Medicare and Medicaid Services (CMS) issued a second Information Collection Request (ICR) with a 30-day public comment period related to the inpatient rehabilitation facility (IRF) Review Choice Demonstration. This demonstration was initially proposed in December 2020 under the Trump Administration. The proposal seeks to require IRFs in selected areas to choose between either 100 percent pre-claim or 100 percent post-payment review for all Medicare Part A fee-for-service (FFS) claims. Under the pre-claim review choice, IRFs could initiate and continue services ...
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CMS Releases FY 2022 IRF PPS Final Rule; Finalizes Much of the Proposed Rule 1.5% Increase in Overall Payments, Finalized QRP Proposals By: Kate Beller, Jonathan Gold, Remy Kerr, and Kristen O’Brien On July 29, the Centers for Medicare and Medicaid Services (CMS) released the Fiscal Year (FY) 2022 Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) final rule. Consistent with the proposed rule, CMS’ final regulation is a relatively straightforward payment update, and also includes a number of changes to the Inpatient Rehabilitation Facility (IRF) Quality Reporting Program (QRP) that are being made in response to the COVID-19 public ...
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By Kristen O’Brien, JD, Vice President, McDermott+ Consulting This week, Senate Budget Committee Chairman Bernie Sanders (D-VT) released the text of the FY 2022 $3.5 trillion budget resolution . The budget resolution is the framework that outlines the spending and savings numbers that the various House and Senate Committees are required to work within to develop the partisan infrastructure reconciliation package. Notably, the focus is what and how much can be spent, which is the main driving focus for healthcare stakeholders. AMRPA is closely watching if Medicare or other healthcare cuts will be used to support the large spending package. What some find most ...
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By Kristen O’Brien, JD, Vice President, McDermott+ Consulting On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) released the CY 2022 Physician Fee Schedule (PFS) proposed rule. This year’s rule includes significant policy proposals addressing telehealth and other COVID-19 flexibilities, updates to the underlying payment data that will impact payment rates, policies promoting health equity, and enhancements and other changes to further develop physician quality initiatives.  Of particular concern in the proposed rule is the 2022 proposed physician conversion factor (CF) of $33.5848, representing a 3.75% reduction from the 2021 CF.  ...
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By Anthony Cuzzola, AMRPA Board Chair AMRPA’s advocacy efforts have continued at an active pace over the first half of 2021, despite the ongoing challenges that COVID-19 has presented to our field. Among our top priorities for 2021 is to work to curtail prior authorization practices by Medicare Advantage plans that delay or deny access to needed IRF care. The AMRPA policy team and members like yourself have engaged in dozens of meetings on Capitol Hill in support of legislation that would take important steps to mandate more oversight of prior authorization. AMRPA has also held multiple meetings with CMS officials this year to draw attention to current practices ...
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By Remy Kerr, MPH, AMRPA Health Policy and Research Manager On June 15, the Medicare Payment Advisory Commission (MedPAC) released its June 2021 Report to Congress . Each year, MedPAC releases an annual March and June report focused on payment policy issues as well as health care delivery system and broader issues impacting the Medicare program. In this year’s June report, there was limited coverage of post-acute care-related policy, and no inpatient rehabilitation hospital/unit (IRF)-specific recommendations. The June report also did not include a chapter on the COVID-19 public health emergency (PHE) or any substantive update on MedPAC’s unified post-acute ...
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By Kristen O’Brien, JD, Vice President, McDermott+ Consulting On Friday, May 28, 2021, President Biden released his Fiscal Year 2022 Budget . This document builds upon the pared-down “ skinny budget ” released on April 9, 2021 and includes $6 trillion in mandatory and discretionary spending. The Department of Health and Human Services (HHS) budget proposes $131.8 billion in discretionary budget authority and $1.5 trillion in mandatory funding, representing a 23% increase in spending compared to FY 2021 levels. A President’s budget is usually seen as an ambitious blueprint setting forth the administration’s policy vision and priorities. Congress still ...
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AMRPA Submits Comments on CMS’ FY 2022 IRF PPS Proposed Rule Recommends CMS utilize 2020 claims data, delay implementation of proposed new QRP measure, and exempt all quarters of 2020 on Care Compare Today, AMRPA submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on the fiscal year (FY) 2022 Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) proposed rule. As covered in detail in the Association’s April 7 Special Edition: Off the Record newsletter , CMS issued a proposed rule with the statutorily required payment-related updates which would result in an estimated 1.8 percent payment increase compared ...
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By Kate Beller, JD, AMRPA Executive Vice President for Policy Development and Government Relations On May 13, Representatives Suzan DelBene (D-WA), Mike Kelly (R-PA), Ami Bera (D-CA) and Larry Bucshon (R-IN) reintroduced the Improving Seniors’ Timely Access to Care Act (H.R. 3173 ).  Following our support for the bill last Congress, AMRPA is already among the 182 endorsing organizations on the bill in the 117 th Congress.  As of May 26, 2021, the bill has 106 bipartisan co-sponsors. Introduction of this legislation is a key 2021 policy priority for AMRPA, and was a major focus during the 2021 Virtual Congressional Fly-In. We thank all our members who ...
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Medical Rehabilitation Management Certification Applications Open June 1, 2021 The American Medical Rehabilitation Providers Association (AMRPA) is pleased to introduce a new certification program for medical rehabilitation management, designed to support new leaders and promote consistency and professionalism in the field. The Medical Rehabilitation Management Certification (MCMR) is intended for current rehabilitation managers as well as clinicians and other professionals who wish to advance their careers by moving into management roles. Successful candidates should demonstrate the knowledge and skills in leadership, strategy, customer service, workforce, ...
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By Kristen O’Brien, JD Vice President, McDermott+ Consulting Last week, President Biden unveiled the American Families Plan (AFP), which ‎represents a $1.8 trillion investment in jobs, child support, education, ‎nutrition and other programs. AMRPA is closely monitoring the legislation for ‎inclusion of health care provisions. Consideration of ‎the AFP impacts the political environment as lawmakers turn to expiring Medicare reimbursement provisions that need to be ‎considered at the end of this year.‎ As outlined, the AFP largely focuses on non-health care related provisions, including the creation of a national family and medical leave program that provides ...
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By Remy Kerr, MPH, AMRPA Health Policy and Research Manager On April 12, Representatives Terri Sewell (D-AL-07) and Vern Buchanan (R-FL-16) reintroduced The Resetting the IMPACT Act of 2021 (H.R. 2455) in the US House of Representatives. This bipartisan legislation is endorsed by AMRPA and would delay the data collection and related development of an IMPACT Act-mandated unified post-acute care (PAC) payment system prototype. The delay would be in effect until a period of time after the termination of the COVID-19 public health emergency (PHE) declaration to ensure differences and changes related to the PHE are better accounted for and to ease demands on all ...
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Biden Administration Releases “Skinny Budget” for FY 2022 Proposal Highlights President’s Topline Priorities for Next Year By Kristen O’Brien, JD Vice President, McDermott+ Consulting Last Friday, April 9, the Biden administration released a proposal of their $1.5 trillion Fiscal Year (FY) 2022 budget. In recent administrations, rather than put out an in-depth budget proposal, presidents have chosen to put forward so-called “skinny budgets” that highlight topline funding levels and priorities but are not actual dollar amounts that are provided to agencies or programs. This year’s skinny budget from the administration is different from those in years ...
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By Kristen O’Brien, JD Vice President, McDermott+ Consulting Last week, the Centers for Medicare and Medicaid Services (CMS) released the FY 2022 proposed rule for inpatient rehabilitation facilities (IRFs), which updates payment rates, make adjustments to the case mix group (CMG) weights, and includes proposals for the IRF Quality Reporting Program (QRP). Compared to past rules, this proposal was fairly light on significant new policy developments but does include a number of important changes for rehabilitation medicine providers. AMRPA provided a detailed summary of all the provisions in the rule via its On the Record Special Edition update, but this ...
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By Lisa Werner  It is important to keep the patient’s plan of care at the heart of the team’s decision making. While each team member creates their own discipline-specific plan of care, it is incumbent on each member to know what the plans written by other team members include. Each team member is responsible for ensuring continuity of care in order to effectively and efficiently achieve the best outcome in the shortest amount of time. To do this, all team members must work together. Be sure that your team conference includes a review of the patient’s plan of care, barriers to achieving the plan, and strategies to help the patient progress with his/her plan. ...
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By Remy Kerr, MPH, AMRPA Health Policy and Research Manager On March 15, the Medicare Payment Advisory Commission (MedPAC) released its March 2021 Report to Congress. In the report MedPAC included its standard chapters addressing each of the nine payment systems in the Medicare program, the current status of the Medicare program from which the Commission bases its payment update recommendations, and a status report on the Medicare Advantage and Medicare Part D prescription drug program. MedPAC also included an additional chapter on expansion of telehealth in the Medicare program resulting from the COVID-19 public health emergency (PHE). As expected, MedPAC ...
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By Peter W. Thomas, JD, Principal, and Joe Nahra, Director of Government Relations Powers Law Firm On March 15-17, AMRPA members will attend the 2021 Virtual Spring Conference & Congressional Fly-In to bring the voice of medical rehabilitation professionals and patients to Capitol Hill. Following the Leadership Forum, where diverse perspectives from Members of Congress, key Congressional staff, federal agency officials, industry leaders, and AMRPA senior staff and counsel will be shared, attendees will join their state colleagues to speak with Congressional Members and staff about key issues of importance to the inpatient rehabilitation hospital field. ...
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Additional Guidance from CMS Changes Coding Methodology for COVID Patients By Lisa Werner  In last month’s blog post, I covered coding for COVID-19. Since that time, the following additional guidance from CMS was issued that changes the methodology for coding patients with active or a history of COVID-19. U07.1 – COVID-19: The first diagnosis code released was intended for patients diagnosed with the virus. Currently, it is used for patients with active virus. For inpatient rehabilitation providers, this code is used when a patient with active virus is in the hospital or unit. It may also be used as an etiologic diagnosis to explain why a patient was admitted. ...
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By Peter W. Thomas, JD, Principal, and Joe Nahra, Director of Government Relations Powers Law Firm On December 14, 2020, the Centers for Medicare and Medicaid Services (CMS) solicited public feedback on the agency’s intention to develop and implement a Medicare “Review Choice Demonstration” (RCD) for inpatient rehabilitation facilities. This demonstration would seek to ensure proper payment for inpatient rehabilitation hospital services by requiring IRFs impacted by the demonstration project to undergo 100% pre-claim or post-payment review. In comments submitted on February 16, AMRPA strongly opposed this demonstration, asking CMS to fully withdraw the ...
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By Kristen O’Brien, JD Vice President, McDermott+ Consulting It was a complex beginning to 2021, with a new administration and Congress.  President Biden formally took office, the COVID-19 pandemic raged on, and Congress rappelled divided chambers and a pending impeachment trial. This environment sets the stage for a challenging legislative and policy agenda, with numerous implications for health care and rehabilitation medicine.  COVID-19 The COVID-19 pandemic remains the dominant and most immediate issue for policymakers. On day one, President Biden released numerous executive actions aimed at fighting the public health emergency with significant focus ...
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