AMRPA Magazine | March 2020

March 2020 • Vol. 23, No.3

Spring Conference

& Congressional Fly-In

Watergate Hotel • Washington, DC

Register Today March 22-24, 2020 amrpa.org/spring-2020

March 2020 • Vol. 23, No. 3

The official publication of the American Medical Rehabilitation Providers Association (AMRPA) Robert Krug, MD Chair, AMRPA Board of Directors, President and CEO Mount Sinai Rehabilitation Hospital Medical Director, PM&R Service Line John Ferraro, MS AMRPA Executive Director Kate Beller, JD AMRPA Executive Vice President for Government Relations and Policy Development Remy Kerr, MPH AMRPA Health Policy and Research Manager Patricia Sullivan AMRPA Senior Editor

Table of Contents Letter from the Chair

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Legislative Update

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FY 2021 Budget Proposals Impacting Rehabilitation and Disability

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Time to Think Ahead

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Patient Success Story: Colby Fillman An Impossible Embrace

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U.S. News & World Report Releases Proposed New Ranking Methodology for Rehabilitation Hospitals for 2020-2021

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Medicare Plans to Merge Provider Compare Sites

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2020 Spring Conference Fly-In

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Brian McGowan Design and Layout AMRPA Magazine, Volume 23, Number 3

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AMRPA Magazine / March 2020

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Letter from the Chair

Robert Krug, MD President and CEO Mount Sinai Rehabilitation Hospital Medical Director, PM&R Service Line

Ripple Effects In a recent issue of the Journal of the American Medical Association (JAMA), a set of articles analyzed an issue that has received significant consideration from our Association and many other health care stakeholders in recent months – prior authorization. While much of the attention has been focused on the clinical and administrative burdens created by these policies, the JAMA articles were wholly focused on the impact prior authorization has on patients and caregivers. Notably, but not surprisingly, one article1 found that “the financial toll, emotional distress, and psychological effects [created by prior authorization policies] on patients can be substantial and recourse can be limited.” A second article2 called more broadly for efforts to “promote transparency, efficiency, and fairness” in prior authorization policies, such as by “requiring the cases be reviewed by someone of the same specialty who has knowledge of the condition and medication.”

As chairman, I’ve made the patient perspective one of the focal points of AMRPA advocacy and communications this year. To that end, the impact of prior authorization policies on our patients – particularly in the Medicare Advantage (MA) program – is our primary focus when engaging with Congress and policymakers in 2020. I’ve been heartened to see the bipartisan backing and support from approximately 400 organizations for H.R. 3107, the Improving Seniors’ Access to Timely Care Act, and I spent time on Capitol Hill in recent months championing for revisions that could make a real-world impact on our patients. For example, while I’ve heard broad agreement that “timely” prior authorization decisions are needed, it’s critical to consider what “timely” means for potential inpatient rehabilitation patients and their caregivers as they wait for a plan decision in an acute hospital setting.

I’ve watched MA beneficiaries wait one to three days – and even longer when they become ready for discharge on a weekend – for a final prior authorization determination on their claim. This timeframe is completely unworkable and unnecessary, and significantly increases the likelihood that patients are discharged to a less appropriate setting. The clinical impact on the patient – as well as the emotional toll for caretakers – presents a clear impetus for reform. This was my focus during my recent Congressional visits on behalf of AMRPA, and I urge members to emphasize these types of patient impacts in your own outreach with your elected officials.

The need for patient-focused advocacy is even more important in light of a recent proposal in the FY 2021 Department of Health and Human Services (HHS) budget that would expand the use of prior authorization for inpatient rehabilitation services to the traditional fee-forservice Medicare program. Such effort would expose millions more beneficiaries to the risk of delayed or denied access to inpatient rehabilitation and other impacts described in the JAMA article. AMRPA has and will continue to highlight the patient impact of prior authorization as our association tackles this issue on multiple policy fronts, and I look forward to continued discussion both among members and with policymakers this month at our Spring Conference.

1

Changing the Game of Prior Authorization: The Patient Perspective. Martha E. Gaines, JD, LLM; Austin D. Auleta, BA; Donald M. Berwick, MD, MPP. JAMA. Published online February 3, 2020. doi:10.1001/jama.2020.0070

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Refocusing Medication Prior Authorization on Its Intended Purpose. Jack S. Resneck Jr, MD. JAMA. Published online February 3, 2020. doi:10.1001/ jama.2019.21428

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AMRPA Magazine / March 2020

Find new and exciting opportunities in AMRPA’s Career Center.

Our Career Center provides services and resources to help the medical rehabilitation field meet their professional goals.

All rehabilitation professionals may browse and apply for jobs at no cost, and AMRPA members will receive discounted rates for posting positions.

Visit our Career Center Here:

careercenter.amrpa.org

Begin by creating your free Career Cast account, which can be found on the top right hand corner of the website.

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AMRPA members will receive a 50% discount on all job postings.

For questions about our Career Center, please contact Elizabeth Katsion, AMRPA Member Services Associate, at ekatsion@amrpa.org or 202-207-1102.

AMRPA Magazine / March 2020

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Legislative Update

Martha M. Kendrick, Esq., Partner, Akin Gump Strauss Hauer & Feld LLP

Highlights: »»

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resident Trump’s Fiscal Year (FY) P 2021 Budget Proposal would reduce discretionary funding for the Department of Health and Human Services (HHS) by 9% or $9.5 billion. Budget savings include a provision that would hit the post-acute care sector hard by establishing a unified post-acute care payment system (-$101 billion).

The Senate impeachment trial wrapped up on February 5, ending with the acquittal of the president on both articles of impeachment. Senators voted largely along party lines, with Sen. Mitt Romney (R-UT) the only Republican to vote to convict.

President Trump’s State of the Union address called on Congress to pass Sen. Grassley’s drug pricing legislation and touted the administration’s health care price transparency proposals, among other health care policy initiatives.

The House Ways and Means Committee released alternative surprise billing legislation; the House Education and Labor Committee also announced a surprise billing proposal that tracks closely to the bicameral compromise of the House Energy and Commerce and Senate Health, Education, Labor and Pensions (HELP) Committee.

AMRPA Magazine / March 2020

FY 2021 Budget Proposal Includes PAC Reductions On February 10, 2020, President Trump released his annual Budget Proposal for the upcoming Fiscal Year (FY) 2021. The $4.8 trillion President’s Budget seeks to realign spending across both domestic and foreign aid programs, and attempts to eliminate a nearly $1.1 trillion deficit over 15 years. This is the only time since the president took office, that he has been able to develop a budget knowing exact spending levels. He signed a two-year funding deal into law in December 2019, and while he honors the military spending limit of $740.5 billion, the president proposes an additional $44.5 billion cut to non-defense programs for FY 2021. Although the president touted leaving Medicare alone, the Budget actually does propose $450 billion in cuts over a decade to the entitlement program, along with $92 billion in cuts to Medicaid.

Of concern to AMRPA, the Trump administration once again proposes to address “excessive” payments to post-acute care providers by establishing a unified payment system. According to the proposal, skilled nursing facilities, home health agencies and inpatient rehabilitation facilities will receive a lower annual Medicare payment update from FY 2021 to FY 2025. A unified post-acute care payment system would include all four post-acute care settings beginning in FY 2026. The proposal is expected to save over $101.5 billion over 10 years. Other notable assumed savings in the proposal include a repeat of the 2020 proposal expanding prior authorization to additional Medicare fee-for-service items at high risk of fraud, waste and abuse. The Budget specifically proposes to expand the Medicare program's authority to conduct prior authorization on certain items or services that are prone to high improper payments, including, inpatient rehabilitation services, for an expected savings of $13.7 billion over ten years. The Budget also assumes $135 billion in savings from an unspecified drug pricing proposal.

The Budget proposal aims to enhance quality improvement oversight at post-acute care facilities, including, IRFs, skilled nursing facilities and home health agencies, by providing the secretary with the authority to levy civil monetary penalties to address poor performance and quality of care concerns. The administration assumes $9.4 billion over 10 years in savings for modifications to the site neutral payment exceptions criteria for long-term care hospitals (LTCHs) by requiring at least an eight-day stay in an intensive care unit (ICU), rather than the current three-day requirement.

The Budget proposes a $22 million cut to the National Institute on Disability, Independent Living and Rehabilitation Research (NIDILRR), which currently receives $112 million in annual funding. The Budget request for the Traumatic Brain Injury program the Limb Loss Resource Center and the Paralysis Resource Center remain at 2020 levels. For the past few budget cycles the Trump administration has proposed to eliminate the Agency for Healthcare Research and Quality (AHRQ). For FY 2021, the administration proposes creation of a new agency called the National Institute for

Research on Safety and Quality (NIRSQ), which consolidates some of AHRQ’s function with the National Institute of Health (NIH), and would focus on value-based care and safety research.

The budget would transfer $98 million from the Patient Centered Outcomes Research Institute (PCORI) to NIRSQ. The Budget also proposes to assess a penalty on physicians and practitioners who order high-risk, high-cost items or services or supplies without proper documentation, such as encounter data or diagnosis. The penalty would be would be $50 for Medicare Part B items/services and $100 for Part A services. Current law does not allow Medicare to hold a health care practitioner financially responsible for improper documentation for ordered items or services. The administration requests $2 million more in funding for the Office of Medicare Hearings and Appeals (OMHA), as well as several informs intended to streamline the appeal process. This includes a fee of 10% of the administrative cost of an appeal for any providers that receive unfavorable outcomes to their appeals at the Administrative Law Judge (ALJ) or Departmental Appeals Board (DAB), which HHS estimates will save $20.4 million over a decade. The Budget also calls for an additional $28 million for the Office of Inspector General (OIG) in order to conduct additional oversight of Medicare and Medicaid Services.

It is important to note that the President’s Budget request is often considered aspirational and will unlikely be fully implemented

by Congress. Lawmakers will consider the proposals and use (or not!) the document to make FY 2020 funding decisions during the upcoming Appropriations process.

President Trump’s State of the Union Address Promotes Health Policy Initiatives On February 4, President Donald Trump delivered the State of the Union Address before a Joint Session of Congress. On health care, the president highlighted falling health insurance exchange plan premiums, and he pledged to protect Americans with pre-existing conditions and to preserve Medicare and Social Security. The president also touted the administration’s initiatives to promote health care price transparency. President Trump contrasted his administration’s health care policies with “Medicare-for-All” proposals, stating that more than 130 members of Congress have endorsed legislation to “impose a socialist takeover” of the health care system. He also criticized proposals to provide free health care to undocumented immigrants. The president noted that the Food and Drug administration (FDA) has approved a record number of generic drugs. He called on Congress to take additional action to lower prescription drug prices and stated that he has been in negotiation with Sen. Grassley and others to advance bipartisan legislation. With respect to the opioid crisis, President Trump pointed to recent declines in overdose deaths, particularly in hard-hit states such as Ohio and Pennsylvania.

The president highlighted the coronavirus outbreak in China and noted that the administration is coordinating with the Chinese government to contain the disease and protect American citizens. In addition, he briefly mentioned government initiatives

related to kidney disease, Alzheimer’s disease, mental illness, and childhood cancer, and reiterated his administration’s goal of eradicating AIDS by the end of the decade.

Surprise Medical Billing Proposals Move through House Committees House Committees of Jurisdiction have been focused once again on surprise medical billing – with mark-ups held on each Committee’s respective proposal. The House Ways and Means Committee marked-up and approved its version by voice vote, which creates an arbitration system for resolving out-of-network claims, on February 12. This proposal, although considered more provider-friendly, has received pushback from the White House for being arbitration-centric. The Education and Labor Committee mark-up occurred on February 11. Its legislation – The Ban Surprise Billing Act – adheres closely to the House Energy and Commerce and Senate HELP Committees’ compromise, which relies on a benchmark payment rate for out-of-network bills and an independent arbitrator, if necessary. The bill includes two mechanisms to resolve payment disputes: For amounts less than or equal to $750 (or $25,000 for air ambulance services), the bill relies on a the median in-network payment rate. For amounts above $750 (or $25,000 for air ambulance), the parties may elect to use an independent dispute resolution process. The legislation also takes steps to address ground ambulance surprise bills.

During the mark-up some Members unsuccessfully advocated for amendments that would have expanded arbitration, an approach favored by hospitals and other providers. The Committee approved the amendment in the nature of a substitute and reported the bill out of Committee by a vote of 32 to 13.

Bipartisan Legislation Introduced to Place Guardrails on CMS Innovation Center On February 3, Reps. Terri Sewell (D-AL), Adrian Smith (R-NE), Tony Cárdenas (D-CA) and John Shimkus (R-IL) introduced the Strengthening Innovation in Medicare and Medicaid Act (H.R. 5241) in order to reign in the Secretary of the Department of Health and Humans Services’ (HHS) ability to implement farreaching demonstrations through the Centers for Medicare and Medicaid Service’s (CMS) Innovation Center. The legislation would limit demonstrations to five years and prohibit the agency from moving beneficiaries into a demonstration program just to obtain a statistically viable sample. Demonstrations would also have to be monitored for access to care issues. The bill creates an expedited disapproval process for Congress, and requires a new process for advance public notice and an opportunity for public comment on the establishment, testing, implementation, evaluation and expansion of a demonstration. The co-sponsors are pushing for the legislation to be included in the May health care package that is coming together to address expiring health care extenders.

CMS Administrator Calls Prior Authorization Practices “Indefensible” During a recent keynote before members of the American Medical Association (AMA), CMS Administrator Seema Verma clearly stated her frustration about prior authorization practices.

She explained that, “The prior authorization process became

AMRPA Magazine / March 2020

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indefensible years ago. Patients are frustrated and doctors are sick of pointlessly wrangling with insurance companies.” Further, she added that, “Prior authorization requirements are a primary driver of physician burnout, and even more importantly, patients are experiencing needless delays in care that are negatively impacting the quality of care they receive.” Administrator Verma confirmed the agency would be making prior authorization changes this year, and noted automation as a possible solution.

Further MA and Part D Updates Released On February 5, 2020, CMS released its proposed rule that updates Medicare Advantage (MA) and the Part D program for Contract Years 2021 and 2022. The rule proposes to foster new MA plan options for individuals with end-stage renal disease (ESRD); update the MA and Part D quality rating system; and permit a second, “preferred” specialty tier in Part D, among other changes. Comments are due April 6, 2020.

As we go to press, AMRPA continues to lobby actively on H.R. 3107, the bipartisan House prior authorization legislation that could move through Congress this year. Sponsor Rep. Suzan DelBene (D-WA) spoke in support of the bill during the House Ways and Means Committee markup on February 12, explaining that the legislation would establish “meaningful guardrails” for the use of prior authorization in Medicare Advantage. She asked Chair Richie Neal (D-MA) to include the bill in final surprise billing legislation. Chairman Neal replied that he is working with Ranking Member Kevin Brady (R-TX) on the issue and would like to address it in the future. He also expressed concern that HHS has not finalized standards for electronic prior authorizations.

Affordable Care Act Developments The Supreme Court will use its private conference on February 21 to consider whether to hear Texas v. United States during the current term. The lawsuit was brought by Republican state attorneys general who argue that the Affordable Care Act (ACA) is no longer constitutional after the so-called individual mandate penalty was zeroed out in 2017. If four justices vote to review the case during the current term, a final decision could be handed down in June 2020. Meanwhile, GOP-led states and the Department of Justice are urging the Supreme Court to wait for lower courts to weigh in before taking up the case. In December, the Court of Appeals for the Fifth Circuit remanded the case back to the Texas district court to reconsider the scope of the severability of the individual mandate from other provisions of the 2010 law.

Medicaid Block Grants Now an Option for States On Jan. 30, CMS released a long-awaited Medicaid block-grant waiver proposal, known as the “Healthy Adult Opportunity” Demonstration Initiative. The optional demonstration will allow states to request that a portion of their funding is capped in exchange for more flexibility to administer their Medicaid programs. The demonstration is limited to the ACA’s Medicaid expansion population, and individuals enrolled in Medicaid for a disability or long-term care services, as well as traditional populations like children and pregnant women, will not be eligible.

The demonstration provides states the option to waive a number of Medicaid program requirements, such as retroactive coverage periods, “nominal” premiums and cost-sharing. States will also have the opportunity to customize the benefit package for those covered and restrict formularies, which potentially allows them to exclude coverage of some prescription drugs. The demonstration proposal is expected to face immediate legal challenges, however, which may delay or derail its implementation.

*** Although the President’s Budget is often considered “dead on arrival,” it does contain policies and “pay-fors” that lawmakers could use for future legislation. As noted above, Congress will have to make several difficult funding decisions in the coming months and weeks. With a ballooning deficit, any increase in spending will likely be balanced with funding reductions. As expected, the post-acute field is yet again a potential target for budgetary cuts.

We urge AMRPA members to register for the upcoming Leadership Conference and Advocacy Fly-In which will be held in Washington, DC, March 22-24, 2020. AMRPA needs your leadership and direct advocacy with your Members of Congress.

We will help set up meetings for you and your colleagues on Capitol Hill with your Members of Congress and Senators, and brief you on the field’s most pressing policy issues, including the President’s Budget.

We hope to see you in Washington, D.C. in March!

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AMRPA Magazine / March 2020

AMRPA Schedule of Events CONFERENCE DATES 2020 Spring Conference and Congressional Fly-In March 22-24, 2020 Washington, DC REGISTER TODAY! AMRPA 2020 Fall Conference October 4-7, 2020 Renaissance Dallas Hotel Dallas, Texas CALL FOR ABSTRACTS NOW OPEN! AMRPA REGIONAL MEETING SERIES Friday, May 8, 2020 Nashville, Tennessee Hosted by HCA Healthcare Friday, June 5, 2020 West Orange, New Jersey Hosted by Kessler Institute for Rehabilitation Wednesday, July 15, 2020 Denver, Colorado Hosted by Vibra Rehabilitation Hospital of Denver MEMBERS-ONLY CALLS Wednesday, March 11, 2020, Noon - 1:00 p.m. ET Wednesday, June 3, 2020, Noon - 1:00 p.m. ET Wednesday, September 13, 2020, Noon - 1:00 p.m. ET Wednesday, November 10, 2020, Noon - 1:00 p.m. ET eRehabData® CLINICAL TRAINING WEBINAR SERIES Free for eRehabData subscribers only Tuesday, March 3, 2020: Managing the Patient Experience Tuesday, April 7, 2020: Nursing and Therapy Documentation Tips Tuesday, May 5, 2020: Physician Documentation Tuesday, June 2, 2020: Managing Outcomes with eRehabData Visit eRehabData.com for more Information.

Please visit www.amrpa.org for registration information.

AMRPA Magazine / March 2020

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FY 2021 Budget Proposals Impacting Rehabilitation and Disability

Peter W. Thomas, JD, Principal, Powers Pyles Sutter & Verville, PC

The Trump administration’s FY 2021 budget proposals impact a wide variety of programs that affect rehabilitation and disability providers and consumers, although perhaps more indirectly than some of the proposals involving Medicare, such as Post-Acute Care (PAC) payment reform and prior authorization in the fee-for-service program. Following is a summary of some of the many rehabilitation and disability-related proposals the administration has put forward for Congressional consideration. While many of these proposals will not survive the appropriations process, the administration has significant regulatory authority to proceed with its agenda without congressional approval and the budget serves as a roadmap for the administration’s intentions.

Rehabilitation and Disability Research and Services This year’s budget would be more alarming if the administration were proposing its domestic (non-defense) funding levels for the first time. The fact is that the Trump administration has proposed many significant cuts to a wide variety of federal rehabilitation and disability programs in the last three years only to be overridden by Congress. While many proposed funding levels continue to be gravely concerning, they are (again this year) not likely to be enacted into law as the onus now shifts to Congress to determine funding levels for agencies and program for the coming fiscal year, which begins on October 1, 2020.

Joseph Nahra, Legislative Director, Powers Pyles Sutter and Verville, PC

The FY 2021 budget proposes a $2.9 billion cut to the National Institutes of Health, bringing the total NIH budget from nearly $42 billion down to $38.7 billion, a huge cut on a percentage basis that would eliminate a wide variety of grants. The National Institute of Child Health and Human Development (NICHD) is slated for a $140 million cut in funding, bringing its budget down to $1.41 billion. NICHD houses the National Center for Medical Rehabilitation Research (NCMRR) which receives a 6.5 percent set-aside of the NICHD extramural research budget and, therefore, rehabilitation research would also be negatively impacted. These cuts would wipe out the $2.7 billion increase in funding Congress and the president just enacted in December 2019. In sum, it is highly unlikely that Congress will reverse course on its recent bipartisan support for increases in NIH funding and there will be plenty of stakeholders making that case.

The National Institute for Disability, Independent Living and Rehabilitation Research (NIDILRR) is housed in the Department of Health and Human Services’ Administration for Community Living (ACL). NIDILRR supports applied research and data collection in the rehabilitation and disability areas. It has funded the Traumatic Brain Injury, Spinal Cord Injury and Burn Model Systems for years as well as investigator-initiated research in the areas of rehabilitation, disability, and independent living. NIDILRR has received increases to its budget of $3 million for each of the last two years, bringing its total budget this year to $112 million. However, the FY 2021 budget proposes to slash NIDILRR funding by $22

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million, to $90 million. This would be a devastating blow to this vital agency for people with disabilities and the providers who serve them. Like NIH, this proposed cut in funding is very unlikely to survive due to bipartisan support in Congress for NIDILRR. There are some relatively positive signs in the FY 2021 budget for the administration for Community Living. While developmental disability programs are, once again, slated for significant funding decreases, the TBI state grants, the Paralysis Resource Center and the Limb Loss Resource Center were all flat funded, i.e., given the same budget as this current fiscal year. This equates to $11 million, $7 million and $4 million, respectively.

In prior years, the current administration proposed to “zero fund” the two resource centers, which would have discontinued those programs, and significantly cut the TBI state grants. However, with AMRPA and many other stakeholders opposing these cuts each year, Congress has saved these programs by either restoring the proposed funding cuts or even increasing annual funding for these programs. The Trump administration finally appears to realize that Congress supports these programs and chose not to propose another bloodbath in funding this coming fiscal year.

Restructuring Research Programs For the first two years of the Trump administration, the budget proposed to move NIDILRR to the NIH and couple the Agency for Healthcare Research and Quality (AHRQ) and the National Institute of Occupational Safety and Health (NIOSH), creating a new agency focused on quality and safety at NIH. These past budget proposals also mentioned blending this new agency into the existing NIH structure and eventually eliminating a separate budget for these programs. The rehabilitation and disability community, led by the Disability and Rehabilitation Research Coalition (DRRC)—of which AMRPA is an active member—strongly opposed this proposal.

Congress agreed and explicitly stated in FY 2019 report language its disapproval of relocating NIDILRR. This year, the budget did not address the movement of either NIDILRR or NIOSH to NIH, but it still contains a proposal to move the AHRQ to NIH. The FY 2021 Budget consolidates the activities of the AHRQ into the NIH structure as the new National Institute for Research on Safety and Quality.

Centers for Disease Control and Prevention: Chronic Disease and Health Promotion Despite the recent focus on infectious disease due to the coronavirus outbreak in China and throughout the world, the president’s budget proposes significant cuts in funding for the Centers for Disease Control and Prevention (CDC). The overall discretionary funding level for CDC would be slashed by more than $1.2 billion, down almost 19% from the FY 2020 level of over $6.9 billion. The budget also seeks to pare back funding for perceived non-priority focuses within CDC, instead targeting funding increases to combatting infectious diseases and specific public health crises, like the HIV epidemic. Specific programs receiving funding increases include immunization and respiratory diseases ($40 million), domestic HIV/AIDS efforts ($279 million), and child vaccines ($533 million), while the National Center for Birth Defects and Developmental Disabilities would be cut by $49 million and the CDC’s environmental health efforts would be cut $31 million.

Most surprisingly, the budget includes a proposal to drastically reduce CDC-wide funding for chronic disease prevention, suggesting a 34% cut for a total funding level of $813 million (down from $1.24 billion in FY 2020). Within this budget line lies a proposal to implement the “America’s Health Block Grant,” which would consolidate funding for a variety of chronic diseases into a single block grant for states. While the administration proposes that this will serve as an opportunity to reform state-based chronic disease programs and would “provide states flexibility” to address chronic diseases highly prevalent in their populations, it mirrors the administration’s efforts to convert Medicaid funding to a block grant. The overall funding for these efforts is also significantly reduced through the block grant proposal from what was available in the past for multiple diseases including tobacco control, heart disease and stroke, diabetes, and arthritis. This elimination of dedicated program funding would likely result in a decreased focus on many of the previously targeted chronic diseases.

Medicaid “Reforms” Prior to the release of the president’s budget, the Centers for Medicare and Medicaid Services (CMS) issued their long-gestating “Healthy Adult Opportunity” proposal, which would essentially allow states the flexibility to convert their Medicaid funding to a block grant. Advocates have decried the proposal as likely to slash services, reduce access to care, and worsen coverage under the Medicaid program, but the administration has pressed on with its efforts (though the waivers are sure to face serious litigation and may not go into effect).

The budget builds on this work, touting the administration’s efforts to “usher in a new era of state flexibility” for Medicaid, and projects that these changes will save a whopping $920 billion over 10 years (which, of course, largely reflects proposed cuts to Medicaid funding and services). Continuing efforts to cap Medicaid funding and institute work requirements on beneficiaries are two linchpins of the administration’s Medicaid vision, and these are sure to remain a major focus of advocates aiming to protect the Medicaid program.

Reform and Expand DME Competitive Bidding The budget contains a number of provisions on Medicare competitive bidding of durable medical equipment (DME), which would go into effect in calendar year 2024. For instance, the budget proposes to change the way Medicare pays for DME under the competitive bidding program, from a single payment amount based on the maximum winning bid to each winning suppliers’ own bid amounts. As a result, Medicare payment to low bidders will equal their low bid amount. This will increase pressure on “low-ball” bidders (whose focus is to gain market share at all costs) to bid more realistically, because they will be held to providing the DME benefit at their bid amount. Currently, all the bids are combined into a composite bid so low-ball bidders routinely get paid more than they actually bid under the program.

The budget would also expand competitive bidding to additional geographic areas, including rural areas, and includes inhalation drugs as a service category for the first time. To reduce burden on suppliers, this proposal also removes the need for a surety bond, which requires all DME suppliers to secure a surety bond for every

AMRPA Magazine / March 2020 11

competition. In the event that fewer than two suppliers submit bids in a rural area, CMS will base prices on information from similar rural areas. Expanding competitive bidding will allow CMS to base prices for DME items and services in rural areas on competition in those areas rather than setting fee schedule prices in rural areas based on competition in urban areas. This is expected to save the Medicare program $7.7 billion over ten years and Medicaid $435 million over ten years.

Another DME budget proposal would allow CMS to annually update DME fee schedules based on retail prices through rulemaking, without using the “inherent reasonableness” (IR) process, a cumbersome regulatory process that requires CMS to amass sufficient evidence before altering fee schedule amounts.

The budget documents state that this change will allow Medicare prices to adapt to rapidly changing and often cheaper technology and reduce Medicare costs as DME prices drop in the retail market. It is projected to save $1.6 billion for Medicare savings and $85 million in Medicaid over 10 years. The reality is that CMS seeks to take advantage of the discounted prices available on the internet for certain types of DME. This, of course, fails to consider the expense built into the fee schedules for the clinical expertise and service element that often accompanies the proper selection, fit and training of various types of DME. There are two additional significant DME proposals in the budget. The first proposal would allow CMS flexibility in the enforcement of the face-to-face physician visit requirement for most Medicare providers and beneficiaries when obtaining a prescription for certain DME, eliminating what CMS now calls an “overly burdensome requirement.” While this is not expected to save the Medicare program any money, it is designed to be less burdensome on providers and beneficiaries. The face-toface requirement was originally established to reduce fraud and abuse. This indicates how strongly the current administration views reduction of provider burden as a priority. Finally, the budget includes a provision that would require CMS to issue additional guidance around the Medicare coverage process, including sub-regulatory guidance on the evidence standards that CMS utilizes in assessing coverage and the process to appeal coverage determinations, in an effort to improve clarity around Medicare coverage.

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Prescription Drug Pricing Rather than proposing specific provisions to lower prescription drug prices as the administration did in last year’s budget, the 2021 budget simply includes an allowance for savings of $135 billion over 10 years for bipartisan drug pricing proposals. The administration supports legislative efforts to improve the Medicare Part D benefit by establishing an out-of-pocket maximum, improving incentives to contain costs, and reducing out-of-pocket expenses for Medicare beneficiaries, mirroring the proposals in the Senate Finance Committee’s legislation. The administration also supports changes to bring lower-cost generic and biosimilar drugs to patients. The budget documents state that these efforts would increase competition, reduce drug prices, and lower out-of-pocket costs for patients at the pharmacy counter, but the administration appears to be punting to Congress to determine exactly how to achieve these goals.

Graduate Medical Education Effective in FY 2021, the budget proposes to consolidate federal graduate medical education spending from Medicare, Medicaid, and the Children’s Hospital Graduate Medical Education Program into a single grant program for teaching hospitals. Total funds available for distribution in FY 2021 will equal the sum of Medicare and Medicaid’s 2017 payments for graduate medical education, plus 2017 spending on Children’s Hospital Graduate Medical Education, adjusted for inflation. This amount will then grow at the CPI-U minus one percentage point each year. Payments will be distributed to hospitals based on the number of residents at a hospital (up to its existing cap) and the portion of the hospital’s inpatient days accounted for by Medicare and Medicaid patients.

The new grant program will be jointly operated by the administrators of CMS and the Health Resources and Services Administration (HRSA). The budget asserts that these changes modernize graduate medical education funding, making it better targeted, transparent, accountable, and more sustainable.

However, these changes are also expected to save $52.2 billion in government-wide savings over 10 years which constitutes a huge reduction in financial support for graduate medical education.

2020 Fall Educational Conference & Expo

Renaissance Dallas Hotel • Dallas, TX • October

Abstract Deadline: April 27, 2020

4-7

What would you like to discuss this year?

Submit your abstracts for AMRPA’s 18th Annual Educational Conference & Expo!

AMRPA encourages you to share your knowledge, case studies, and experience in these 6 categories:  Business Operations and Leadership Development  Clinical Care Delivery — A Team Approach  Regulatory, Legislative and Accreditation Matters  Marketing and Relationship Management  New for 2020! Technology, Research and Innovation  Other: Topics Outside the Box

Submit your ideas today!

For more information about how to submit your abstract, visit the AMRPA website: https://amrpa.org/Education/Events/Fall-2020-Call-for-Abstracts For questions about submitting an abstract, contact AMRPA Education Specialist Kirsten Lew at klew@amrpa.org.

#AMRPA

AMRPA Magazine / March 2020 13

Time to Think Ahead

Lisa Werner, MBA, MS, SLP Director of Consulting Services, Fleming-AOD, Inc.

If you feel like you have finally caught your breath from the changes to the Case Mix Groups (CMGs) that went into effect on October 1, 2019, make sure you don’t plan to rest for long. I was working with a client last week and we included a planning meeting to review the Final IRF-PAI Version 4.0 that was released in early December. The changes will not impact patient care, but they will require forethought and documentation changes as they call for a significant amount of data collection. To put this into perspective: the length of the document is 30 pages, which is up from 18 pages in the current version. Some of the items that were used only for risk-adjustment have been introduced for discharge assessments as well. Furthermore, many questions are related to the social determinants of health and the Drug Regimen Review.

Let’s Take a Closer Look at These Changes The first difference starts on page 3, Section A, where the ethnicity, race and preferred language questions have been added or modified. On the current IRF-PAI, patient race is asked in a different manner. Therefore, you should evaluate whether the expanded questions should be answered by the provider currently assigned to complete the question or if a different provider may have more relevant information. On page 4, a question about transportation has been added. The question aims to determine whether a lack of transportation has interfered with the patient’s ability to manage on a day-today basis. The ethnicity, race and language questions are asked on admission only, but the transportation question is asked at admission and discharge. If these questions are currently built into your EMR and populate eRehabData®, please do not overlook the modification that will be necessary. I see value in including the page 3 and 4 questions on the case manager’s admission and discharge assessment.

On page 5, Section B, there are new questions that address the patient’s hearing, vision and health literacy. These are asked in addition to the expression of ideas and wants and understanding verbal and non-verbal content questions, which continue to be presented in the same form as we currently see them. The discharge IRF-PAI asks the health literacy question again. This is the only Section B question that is repeated. In many inpatient rehabilitation units and hospitals, the expression and understanding questions are completed by the nurses. Since the new questions about vision, hearing and health literacy are loosely related, the nurse should be able to answer them without adding to their workload. Once again, the new questions will need to be added to the EMR using the exact answers as seen on the IRF-PAI in order to upload to eRehabData®.

14 AMRPA Magazine / March 2020

Section C is also changing. The signs and symptoms of delirium question from CAM was included in addition to the BIMs and Staff Assessment for mental status. The current provider assigned to complete the BIMs should also be responsible for the CAM. The instructions indicate that the CAM should be answered in addition to either the BIMs or Staff Assessment. Currently, the Section C items are completed at admission only. Beginning for discharges on and after October 1, 2020, the Section C questions are asked again at discharge.

Section D introduces mood questions. Nine questions about the patient’s mood are asked and scored in terms of presence and frequency. Additionally, there is a question about social isolation.

These items may best be answered by a social worker, case manager or nurse depending on your access to services. The Section D items are present for admission and discharge scoring.

The next few items stay the same until we arrive at Section J: Health Conditions. These new questions regarding pain were added to the IRF-PAI in both the admission and discharge sections.

To share the responsibility, these questions could be addressed by physical therapy as they are likely asking these questions in the interview already. Make sure the information is recorded in the evaluation and discharge summary using the same answers as listed on the IRF-PAI to ensure ease of data collection.

In Section K, the list of nutritional approaches has been modified to be more specific.

Make sure to plan accordingly.

The breakdown of this section would not necessitate a change in personnel completing the item, but your EMR might need to be adjusted if this question is answered in the record.

Section N has been expanded

to include questions about whether the patient is taking medication in high-risk drug classes, and if there is a documented indication for these medications. Given the complexity of the high-risk drug class questions, discuss the role of pharmacy and the physician in addressing this new item. If nursing has been completing your drug regimen review questions, you might agree that the new questions call for an assessment that goes beyond the nurse’s scope of practice.

Section O was vastly expanded. Make sure to integrate the list of Special Treatments, Procedures and Programs into your EMR. This section should be completed by the patient’s nurse. It is asked at admission and discharge.

On the discharge IRF-PAI, new questions were introduced to validate hand-off of medications to the next provider. The first two questions ask if a current reconciled medication list was delivered to the next provider and, if so, the route of transmission.

This section also asks if the provider gave a current reconciled medication list to the patient, family or caregiver and the route of transmission. Since the nurse prepared the discharge paperwork, adding these questions to the discharge process is likely the least intrusive means of gaining responses.

This concludes the summary of changes for the IRF-PAI Version 4.0. Of note, I did not indicate each item that is included on the IRF-PAI and skipped sections that have not been modified. Given the extent of the revisions, I felt that it was important to remind you of how many changes we face so you can start pulling teams together to assign task completion and to anticipate necessary documentation changes. As always, these updates impact patients discharged on and after October 1, 2020, which means you will need to have the documentation changes in place and education completed by the end of August. These questions will be required for Medicare fee-for-service and Medicare Advantage patients beginning with September admissions for stays anticipated to be more than 30 days. More instructions are required to ensure that the intent of the new items is properly captured. I look forward

AMRPA Magazine / March 2020 15

Patient Success Story: Colby Fillman An Impossible Embrace The woman travelling north in the Honda CRV abruptly made a left turn in front of Colby Fillman’s south-bound motorcycle.

With no time to brake, Colby collided with the back of her SUV, crashing through the window. His right shoulder smashed into the post between the windows, wrenching it backwards and tearing out from his spinal cord the nerves that operated his right arm. He also broke his left forearm and injured both legs as he collapsed, unconscious, to the pavement.

A few moments later, Colby, unaware and in shock, attempted to get up. He was determined to re-mount his motorcycle, so he wouldn’t be late for his job at Tennessee-American Water, but neither of his arms functioned. Police and ambulance struggled to restrain him, and that’s when he regained consciousness, looking up from the pavement into the face of a police officer forcibly holding him down and shouting at him to be still.

AMRPA Seeking Member Submissions of Patient Success Stories and Testimonials

In 2020, AMRPA wants to feature you!

We are currently soliciting patient success stories and testimonials from AMRPA member hospitals to better showcase the outstanding work of our industry and membership. If you are interested in submitting a success story or testimonial, email Julia Scott, AMRPA Communications Coordinator, at jscott@amrpa.org.

16 AMRPA Magazine / March 2020

Colby spent four days in the hospital where his physician told him he’d never be able to use his right arm again.

Uncomprehending, Colby asked, “And how long will it take before my arm works?” The physician replied, “Never.” Still not understanding, Colby asked when he would be able to move his arm, and received the same negative response. After several back-and-forths, the physician sternly said, “Look, you’ve had a complete avulsion. Your nerves are torn out of your spinal cord.

Your arm is dead. It will never move again. In a year, you’ll be asking me to amputate your arm because you’ll be tired of it hanging lifeless at your side.”

Colby couldn’t grasp this dreadful prognosis as his life sentence because, even though unable to move his right arm, some function in his hand remained. His mother implored the doctor to at least give them a referral for physical therapy, and eventually Colby came to Siskin Hospital for Physical Rehabilitation for outpatient therapy.

How long will it take before my arm works?’

The physician replied, ‘Never.”

Though aware of the prognosis Colby had received, his therapist, Dr. Cheryl Giest, OT/L — a specialist in hand, wrist, elbow and shoulder therapy — knew the medical world had grown by leaps and bounds in this area. She also knew that time was in Colby’s favor since the accident had occurred recently. Often, nothing can be done if a year or more has elapsed. She recommended a surgeon at Emory University, and Colby made an appointment for a medical consultation.

When the surgeon met him, Colby says, he was so excited because Colby presented as a perfect candidate for the new procedures available. He told him that he had performed many surgeries for people in his condition and that Colby would be his poster child. He cautioned him, however, not to expect to ever be able to touch the back of his head or raise his arm over his head. Despite this limitation, Colby felt hope revive.

Colby underwent surgery almost exactly six months after the accident. The surgeon told Colby to expect a six-month recovery period with no sign of improvement, but after that he would see incremental improvement. During the six months’ recuperation period, Colby continued his outpatient therapy at Siskin Hospital.

Because of Siskin Hospital, I can play with my children again.”

Almost to the day, Colby says, he saw improvement when his baby boy, Barrett, was born six months later and Colby raised his arm to hold him.

Now, Colby can do most everything he did before, including touching the back of his head and raising his arm above his head. Besides the surgery, he credits the almost two years of therapy plus his own doggedness in following Dr. Giest’s instructions with assigned homework.

Since the accident, Colby has met other people with amputated arms and found out they’d had the same diagnoses with the same prognoses of arm death and inevitable amputation. Colby is happy to share with them that there are other options besides amputation.

“Because of Siskin Hospital,” says Colby, “I can play with my children again.”

This story was originally published by Siskin Hospital for Physical Rehabilitation.

For more information on the life-changing services provided by Siskin Hospital for Physical Rehabilitation, visit them at siskinrehab.org.

Learn more about the #powerofmedicalrehab by visiting this page on AMRPA’s website.

AMRPA Magazine / March 2020 17

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18 AMRPA Magazine / March 2020

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AMRPA Magazine / March 2020 19

Did You Know?

All of our webinars are available online!

Missed out on a recent AMRPA webinar? Not to fear!

All AMRPA webinars are available On Demand for purchase almost immediately following its recording.

W Eour B selection I N A here: R Browse https://amrpa.org/Education/Webinars/OnDemand-Webinars *AMRPA members receive a discount on all webinar recordings.

20 AMRPA Magazine / March 2020

U.S. News & World Report Releases Proposed New Ranking Methodology for Rehabilitation Hospitals for 2020-2021 AMRPA to Provide Substantive Comment on Proposed Methodology

Kate A. Beller, JD, AMRPA Executive Vice President for Policy Development and Government Relations

In March 2019, U.S. News & World Report announced its intent to shift from relying solely on expert opinion in its rehabilitation hospital rankings and incorporate certain types of objective data in its methodology. As part of this effort, U.S. News has participated in months-long engagement with the American Medical Rehabilitation Providers Association (AMRPA) and other stakeholders to determine what other inputs should be considered as it works to revise its methodology, as well as the appropriate weights for those inputs. The revised rankings will initially focus on what U.S. News views as “high acuity” rehabilitation care.

U.S. News (working in conjunction with its contractor, Research Triangle Institute, Inc. [RTI]) also indicated interest in identifying data sources that could be incorporated in future ranking years, including all-payer registries. Over the course of numerous meetings, an AMRPA workgroup has been providing the U.S. News/RTI team with feedback on: 1) the current data sources and specific measures that U.S. News has identified for consideration; 2) other data sources that should be factored into the rankings in either the 2020-2021 rankings or future years; or 3) operational issues for U.S. News’ consideration, such as the fact that that certain patient populations are not reflected in some of the datasets under consideration. U.S. News expressed strong interest in a number of recommendations set forth from the AMRPA workgroup, such as including stroke as one the conditions that should be considered as part of the hospital’s “high acuity care” (in addition to traumatic brain injury and traumatic spinal cord injury).

Additionally, the U.S. News/RTI team expressed interest in further discussion of some inputs that could be included in current and future ranking editions, such as condition-specific CARF accreditation and teaching status. There was also discussion of implementation/operational issues tied to some of the inputs under consideration, such as taking into account the relationship of a hospital’s patient complexity and number of interrupted stays and other issues involving risk adjustment. U.S. News expressed interest in continuing to work with AMRPA as it finalized the upcoming 2020-2021 methodology, as well as future refinements to the inputs and weights included in its work.

1

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AMRPA Magazine / March 2020 21

U.S. News’ Proposed 2020-2021 Methodology Following AMRPA’s engagement, U.S. News & World Report released a draft methodology on January 28, with the following proposed measures and weights: Expert opinion (50%) Select Outcomes-Based Measures on IRF Compare (20%) Volume Conditions for Stroke, TBI and TSCI as reported on IRF Compare (10%) Certain Patient Services Reported on the American Hospital Association Annual Survey (6%) Certain Advanced Technologies Reported on the American Hospital Association Annual Survey (6%) Select Patient Safety Process Measures Reported on IRF Compare (5%) Designation as a NIDILRR Model System for SCI, TBI or Burns (2%) CARF International Accreditation (2%) Additional information on the datasets/inputs, as well as the rationale provided by U.S. News, are detailed more extensively in the sections below: Eligibility All facilities listed in the AHA annual survey database will automatically qualify for consideration in U.S. News & World Reports Best Hospitals rankings, with the exception of military and federally owned facilities. However, there are eligibility requirements to be considered in the rehabilitation rankings.

Rehabilitation hospitals can qualify through 1) appearing in both the AHA annual survey database and CMS IRF Compare or 2) have an expert-opinion score of 1% or higher based on the three most recent years of U.S. News national physician surveys. Of the eligible hospitals, only those achieving what U.S. News determines to be the “highest scores” will receive a ranking. U.S. News also proposed that in addition to its traditional expert rankings, it will also use data from the annual AHA survey, IRF Compare, and NIDILRR model system designation from eligible hospitals.

Structural Measures In its designated “structure” portion of its ranking, U.S. News has proposed to put an emphasis on volume, with volume of patients treated with stroke, traumatic brain injury (TBI) and traumatic spinal cord injury (TSCI) each making up 3.33% of the rankings (10% total).

U.S. News also proposes to examine patient services reported in the AHA survey, including whether hospitals offer services like patient representative services, translators, case management and several others. The patient management score will be weighted at 6% of the total score. Another 2% of the score will be determined by whether the hospital is designated as a model system by NIDILRR. U.S. News proposed methodology also includes an Advanced Technology ranking worth 6% of the score, which accounts for hospitals’ utilization of robot-assisted walking therapy and electrodiagnostic services, among other technologies. Finally, U.S. News will use CARF accreditation as 1% of the total score. In total, structure measures will be weighted at 25% of the total score.

22 AMRPA Magazine / March 2020

Process Measures The “process” portion of the rankings as proposed will incorporate patient safety measures from IRF compare and its annual expert opinion rankings. U.S. News proposes to use the influenza vaccination rate measures for both health care personnel and patients. Each of these measures will be separately weighted at 2.5%, and calculated using data from IRF Compare. U.S. News acknowledges that the patient influenza rate was recently removed from the IRF Quality Reporting Program (QRP), and will therefore be retired after its inclusion in the 2020-2021 methodology.

Outcomes Measures The “outcomes” measures used in the proposed methodology will make up 20% of the total hospital score. CMS proposes to weight each of the following measures at 6.67% of the total score: Preventing potentially avoidable 30-day hospital readmissions after IRF discharge; Preventing potentially avoidable hospital readmissions during rehabilitation care; and Successful discharge to home and community. All of these measures will be calculated using data from IRF Compare.

Expert Opinion Under the proposed methodology, the annual expert opinion survey (which previously was 100% of the score) would be weighted at 50% of the score. For 2020-2021, U.S. News proposes to base a hospital’s expert opinion score on the average number of nominations from the three most recent annual surveys of board certified physicians conducted for the Best Hospitals rankings. In completing the survey, physiatrists are specifically asked to nominate hospitals in the field of rehabilitation medicine that “they consider best for patients with serious or difficult conditions,” and they can nominate as many as five hospitals.

The sample of surveying physicians for 2020 are drawn from the Doximity Masterfile, and U.S. News expects that the survey will be completed in March.

Anticipated Industry Impact In its proposal, U.S. News provided some insight into how the new methodology likely will (or will not) effect hospital’s current rankings. It calculated scores using the current methodology and currently available data, and provided a comparison between previously ranked and unranked hospitals. This analysis found that previously ranked hospitals “performed better than previously unranked hospitals on nearly every measure that will be used in the new methodology,” particularly with respect to volume. The only exceptions were health care personnel and patient vaccination rate measures and the successful discharge to home and community measure. U.S. News also found the proposed methodology resulted in a two-fold difference in median overall score between previously ranked hospitals and all other hospitals.

Potential Future Refinements to the Methodology During discussions between U.S. News and AMRPA about potential future improvements to the rankings, numerous AMRPA members expressed interest in developing condition-specific rankings. While U.S. News expressed interest in moving to this type of rankings system, it “pragmatically” views this as being “many, many years off.”

U.S. News also expressed interest in incorporating other all-payer datasets into its methodology in future years. AMRPA will be engaging with U.S. News on this issue in the coming months to whether and how this type of data could be effectively captured in the rankings methodology. *** AMRPA staff has closely reviewed the current draft of the U.S. News methodology following its late January release, and will be reconvening a workgroup to develop the Association’s comments and recommendations to U.S. News for the 2020-2021 methodology and future years.

Input

As the table shows, hospitals that were previously ranked in Rehabilitation performed better than previously unranked hospitals on nearly every measure that will be used in the new methodology.

For example, as a group, the previously ranked hospitals treated a median of 59 traumatic brain injury cases and 293 stroke cases among Medicare beneficiaries, compared to medians of 19 and 107, respectively, among previously unranked hospitals. Differences such as these contributed to a two-fold difference in median overall score between previously ranked hospitals and all other hospitals.

On the measure of overall score, even the lowest-scoring previously ranked hospital outranked all but a handful of the previously unranked hospitals in our preliminary 2020 analysis.

Source

Total Weight

Expert Opinion

Average Number of Nominations Received in the 2018, 2019 and 2020 Annual Survey of Board-Certified Physicians Conducted for U.S. News Best Hospital Rankings

50%

Outcomes-Based Measures: • Preventing potentially avoidable 30day hospital readmissions after IRF discharge • Preventing potentially avoidable hospital readmissions during rehabilitation care • Successful discharge to home and community

IRF Compare

20% (each measure counted for 6.67%)

Patient Volume for Stroke, Traumatic Brain Injury and Traumatic Spinal Cord Injury

IRF Compare

10% (each measure counted for 3.33%)

Patient Services • Cardiac rehab • Case management • Enabling Services • Translators • Neurological services • Occupational health services • Pain management program • Palliative care program • Patient-controlled analgesia • Patient representative services • Physical rehab outpatient services • Psychiatric services • Social work services • Wound management services • Health research • Hemodialysis

AHA Annual Survey (Services are counted as “present” if they are available at the facility or health system, or via a partnership, as indicated on the AHA survey)

6%

AMRPA Magazine / March 2020 23

Input

Source

Total Weight

Patient Safety Process Measures • Influenza Vaccination Coverage Among Health care Personnel • Percent of Residents/Patients Assessed & Appropriately Given Influenza Vaccine

IRF Compare

5% (each measure counted for 2.5) Note: the patient influenza rate will be retired next year in the U.S. News Rankings, as it was recently removed from the IRF QRP

NIDILRR Designation • Designation as a Model System in Rehabilitation in the area of Spinal Cord Injury, Burns, or Traumatic Brain Injury

NIDILRR-Reported Data

2%

CARF International Accreditation

AHA Annual Survey

1%

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AMRPA: Working Together to To Preserve Preserve Access To Medical Rehabilitation AMRPA: Working Together Access to Medical Rehabilitation Maggie Ramirez · VP of Membership Services · 347-573-3732 · mramirez@amrpa.org

Elizabeth Katsion, AMRPA Member Services Coordinator, ekatsion@amrpa.org, 202-207-1102.

24 AMRPA Magazine / March 2020

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AMRPA Magazine / March 2020 25

Medicare Plans to Merge Provider Compare Sites

Jonathan M. Gold, JD, AMRPA Director of Government Relations & Regulatory Counsel

Highlights:

»» »»

Quality data for all settings of care will be available via just one website Reporting requirements for providers will remain unchanged

On January 23, Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma announced that the agency intended to merge all existing provider Compare websites – including IRF Compare – into one Medicare-wide provider Compare site.

Currently, there are eight different Medicare Compare sites for different sites and types of care. The current sites include IRF Compare, Hospital Compare, Nursing Home Compare, Home Health Compare, Dialysis Facility Compare, Long-term Care Hospital Compare, Physician Compare and Hospice Compare. The new, combined site will be called “Medicare Compare,” and it is scheduled to be released in spring 2020.

In her announcement, Verma said that although the current Compare sites are popular, the separate sites are not standardized and can be difficult to navigate for consumers. The new site will standardize how quality and other information is presented about providers, and Verma says this will make it easier for beneficiaries to find the information they are seeking. This initiative builds on the broader “eMedicare” initiative that the agency announced in 2018. This initiative has been seeking to make health care information more accessible to consumers and stakeholders, and has rolled out other new products such as the “What’s Covered” mobile application for finding Medicare benefits.

The agency states that the combining of the existing sites will not alter quality reporting requirements for providers, and that all of the currently reported information will still be available to the public. In addition, Verma said that CMS will also be introducing a new site called the “Provider Data Catalog,” which will be designed for use by researchers and stakeholders. Verma’s announcement says this second site will have intuitive search features for data sets, which will also be made available via an application programming interface (API).

CMS has not announced an exact date the new sites will be released, but says it expects the new Medicare Compare site to be available sometime in spring 2020. In addition, Verma said that the agency will continue to run the separate provider Compare sites for an unspecified amount of time after the new sites are available. CMS has begun working with stakeholders, including AMRPA, to collect feedback on the new sites and tools, and says it will continue to accept feedback and make improvements to the sites.

26 AMRPA Magazine / March 2020

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AMRPA Magazine / March 2020 27

Spring Conference

& Congressional Fly-In

Watergate Hotel • Washington, DC

March 22–24, 2020 Register Today

March 22-24, 2020

It's time to come to Washington, DC! AMRPA wants to encourage all current and future medical rehabilitation leaders to attend our annual Spring Conference & Congressional Fly-In, being held March 22-24, at The Watergate Hotel, in Washington, DC. The conference itself is split into two parts – the Medical Directors Symposium and the Leadership Forum, which includes the Congressional Fly-In.

amrpa.org/spring-2020

The Medical Directors Symposium on March 22 is designed for physician leadership within medical rehabilitation units. Whether you're a new or experienced medical director, you will walk away from this symposium with skills and strategies to ensure that you are successful in your medical director role.

Topics to be covered include: Navigating post-acute choice and Medicare red tape How to lower your acute discharge rate Practices to lower your 30-day readmission rates after discharge Medical director's impact on quality care delivery Takeaways from the CMS Quality Summit Following the Medical Director's Symposium, the Leadership Forum and Congressional Fly-In are rare opportunities to hear directly from federal policy makers and industry thought leaders who are diving crucial discussions about the medical rehabilitation industry. This year, AMRPA has secured high-level representatives from a number of federal agencies, including: Centers for Medicare and Medicaid Services (CMS) U.S. Department of Health and Human Services (HHS) Medicare Payment Advisory Commission (MedPAC) National Institute of Child Health and Human Development

28 AMRPA Magazine / March 2020

Adam Boehler, Senior Advisor to the Secretary of Health and Human Services, CMS Deputy Administrator and Director of the CMS Innovation Center, speaks on innovation in post-acute care at the 2019 Leadership Forum.

In addition, we will hear from the National Association of LongTerm Care Hospitals and National Association for Home Care and Hospice.

Alison N. Cernich, PhD, is the Deputy Director of the Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD) at the National Institute of Health. In her presentation, she will discuss the fundamental shift occurring in rehabilitation, in respect to the overall approach to delivering care and the new technologies being integrated in care delivery.

Cernich will cover potential implications of these advances and where the field should be poised during this time of transition.

Also joining us for the Leadership Forum is Ben Harder, Chief

Ben Harder Chief of Data Analysis, U.S. News & World Report

Eric D. Hargan Deputy Secretary, U.S. Department of Health and Human Services

Alison N. Cernich, Ph.D., ABPP-Cn Deputy Director, Eunice Kennedy Shriver National Institute of Child Health and Human Development, National Institutes of Health

Susanne Seagrave, PhD Deputy Director, Division of Institutional Post-Acute Care, Centers for Medicare & Medicaid Services

of rehabilitation hospitals/units and patients. Physicians have a powerful voice and message that needs to be heard. Members of Congress appreciate the clinical expertise of Medical Directors, and in particular, the role we all play in creating policies that lead to improved patient care and outcomes.

The recently released Fiscal Year (FY) 2021 proposed budget and ongoing session in Congress pose both great opportunities and potential threats to the medical rehabilitation industry. It is more important than ever to educate yourself and get involved in the legislative and regulatory processes that affect your day-to-day operations. Make sure your voice is heard!

Thank you to our 2020 Spring Conference sponsors and exhibitors:

Dr. Rich Kathrins, former chair of AMRPA Board of Directors, presents the AMRPA Chairman's Award to Laurence Dylan Wilson, [title, Centers for Medicare and Medicaid Services] at the 2019 Leadership Forum.

of Data Analysis at the U.S. News and World Report. In his AMRPA Spring Conference presentation, Harder will discuss the considerable changes being brought to the U.S. News Best Hospitals for Rehabilitation ranking this summer. Once determined exclusively by a survey of physiatrists, the ranking will now incorporate objective data on patient outcomes and other quality measures, including data elements from CMS IRF Compare and the American Hospital Association Annual Survey Database. He will review key strengths and limitations of the new methodology, discuss feedback U.S. News has received, and comment on actions that hospital leaders might take to help U.S. News advance measurement that's meaningful to both clinicians and patients.

There are still sponsorship and exhibit opportunities available! To learn more, and to register for the 2020 AMRPA Spring Conference & Congressional Fly-In, visit the AMRPA website.

After the Leadership Forum, we head to Capitol Hill. AMRPA will schedule meetings with Senators and Representatives in order to share our top policy priorities and advocate on behalf

AMRPA Magazine / March 2020 29

PAC Market Analysis Reports Find out where your institution stands with a Market Analysis of Medicare Post-Acute Care (PAC) Referral Patterns, Episode Spending, Performance Measures and Impact of Medicare Bundled Payment Models

Using the most recent two years of Medicare claims data, Dobson DaVanzo & Associates delivers inpatient rehabilitation providers with a general market-level analysis on their facility’s episode spending and key performance metrics across all Medicare discharges. Benchmark your facility against state and national inpatient rehabilitation providers and find out where you stand.

Dobson DaVanzo & Associates can also help you better understand how the Bundled Payment for Care Improvement (BPCI) initiative and the Comprehensive Care for Joint Replacement Payment Model (CJR) are impacting the markets.

Stay informed! Order your PAC report today.

AMRPA Members Receive Reports at Discounted Rates.

Visit www.amrpa.org/PAC-Market-Analysis-Reports for more information, or contact Elizabeth Katsion, AMRPA Member Services Coordinator, ekatsion@amrpa.org.

30 AMRPA Magazine / March 2020

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An online community forum enabling a private social network for AMRPA members to form communities, collaborate, manage industry profiles, and connect with peers and colleagues.

On Engage AMRPA, members are also able to:  View AMRPA Upcoming Events  Listen to AMRPA Member’s Only Calls  Read the latest AMRPA Comment Letters  And much more!

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AMRPA Magazine / March 2020 31

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