Looking Ahead to October:
AMRPA’s Recommendations Related to Coverage, Payment & Patient Outcomes Were Incorporated in the FY 2021 IRF Payment Final Rule
On August 4, the Centers for Medicare and Medicaid Services (CMS) released the federal fiscal year (FY) 2021 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Final Rule and accompanying Fact Sheet. The rule will go into effect on October 1, 2020, and is scheduled to be published in the Federal Register on August 10, 2020.
Kate Beller, JD, AMRPA Executive Vice President for Government Relations and Policy Development
Most notably, CMS significantly scaled back its proposal to allow non-physician practitioners (NPPs) to perform certain IRF services that are currently required to be performed by a rehabilitation physician (for example, completing the pre-admission screening). AMRPA raised serious concern about the proposal’s potential impact on patient care and safety, and we conveyed our concerns through our comprehensive comment letter and discussions with CMS and other postacute care stakeholders. AMRPA therefore supports CMS’ decision to significantly limit this proposal to only allow NPPs to conduct 1 of the three required “CMS’s decision to face-to-face physician visits with the patient per directly respond to week, beginning with the second week of the many of our leading patient’s admission to an IRF. Numerous arguments raised by AMRPA in our letter – such as the fact that concerns in its final rule the role and judgment of rehabilitation physicians constitutes a big win are central to the successful outcomes of complex for AMRPA and, most IRF patients – were cited by CMS in the final rule. importantly, the quality Additional detail on this provision is included in the of care provided to summary section below. In addition to the NPP provision, CMS also finalized the removal of the Post-Admission Physician Evaluation (PAPE) consistent with AMRPA’s recommendation. The PAPE requirement was temporarily waived as an IRF coverage requirement under the April 6, 2020, interim final rule in response to the COVID-19 public health emergency (PHE). With the PHE being extended in late July, AMRPA anticipates that the PAPE will remain waived until its permanent removal on October 1, 2020. AMRPA is closely reviewing some other provisions of the rule, including CMS’ decision to codify most
our patients and their outcomes. We applaud CMS for this action and are gratified that CMS leadership recognized the immense value that IRFs and direction under rehabilitation physicians offer.”
— Dr. Robert Krug, AMRPA Board Chair AMRPA Magazine / August 2020 15
