Recent AMRPA Comment Letters

Improving Medicare Post-Acute Transformation Act of 2014

The IMPACT Act requires a series of quality measures and measures of resource use. The Center for Medicare and Medicaid Services (CMS) and its contractors have engaged in a fast-paced process to develop these measures to meet the deadlines established by law. The following regulatory comment letters are in response to IMPACT Act draft measures.

Letter to Abt Associates and CMS in response to the Call for Public Comment on a quality measure, Percent of Residents Experiencing One or More Falls with Major Injury During a Home Health Episode
October 14, 2016
AMRPA Comments

Development and Maintenance of Post-Acute Care Cross Setting Standardized Patient Assessment Data: Data Element Specifications for Public Comment.
September 12, 2016
AMRPA Letter

Collection of Standardized Assessment-Based Data Items   
August 17, 2016

On August 15, 2016, CMS posted on its website a twelve day public comment opportunity for the “Collection of Standardized Assessment-Based Data Items” developed by the agency’s contractor, Rand Corporation. Eleven national organizations, including AMRPA, submitted a letter asking CMS to promptly extend this PAC Impact Act Comment period to at least September 15, 2016.
Coalition Letter

Letter to MedPAC Requesting Further Advisement to CMS Regarding Modeling and Testing Under the IMPACT Act
April 6, 2016

PAC Coalition’s Letter to Congress Highlighting IMPACT Act Implementation Concerns
March 18, 2016

Post-acute care (PAC) consumer and provider advocates sent a letter to Congress outlining the collective concerns with the compressed time frame and measure development process. The same letter was also sent to CMS Acting Administrator Andy Slavitt.
Coalition Letter
Draft Specifications for the Medicare Spending per Beneficiary--Post Acute Care (MSPB-PAC) Resource Use Measures
January 29, 2016

CMS issued a series of questions related to development of a patient experience of care survey for IRFs. We cautioned in our comments that the survey should measure experience, not satisfaction, and provide actionable data to providers to drive quality improvements.
AMRPA Comments

Medicare Program; Request for Information to Aid in the Design and Development of a Survey Regarding Patient and Family Member Experiences with care Received in Inpatient Rehab Facilities, CMS-3328NC, 80 Fed Reg. 72,725 (Nov. 20, 2015)
January 15, 2016
AMRPA Comments
NQF MAP Pre-rulemaking Report Process
December 2015/January 2016
CMS is required to use a consensus body such as the National Quality Forum (NQF) to review measures under consideration for its quality reporting programs.  Each December in advance of the various workgroup meeting, NQF hosts a public comment period to collect feedback to provide to workgroup members to inform their deliberations.  NQF is required to submit a formal report on these measures under consideration by February 1 of each year.  Prior to the submission of its final report NQF makes a draft pre-rulemaking report available for public comment, typically in the first two weeks of January.  AMRPA makes it a point to go on record through both comment opportunities.
AMRPA Comments

Draft Measure Specifications for Discharge to Community Quality Measure for Skilled Nursing Facilities, Inpatient Rehabilitation Facilities, Long-Term Hospitals, and Home Health Agencies
November 23, 2015
AMRPA Comments

Draft Measure Specifications for Readmission Measures
November 16, 2015
AMRPA Letter 

Draft Measure Specifications for Drug Regimen Review
Date of comment opportunity announcement:  October 16, 2015
AMRPA Letter

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Request for Information (RFI) re: Episode Groups.  (Episodes Groups Summary)
February 12, 2016
MACRA requires CMS to develop episode groups and this comment request was seeking input on specific clinical criteria and patient characteristics to classify patients into care episode and patient condition groups.
AMRPA Letter

Request for Information Regarding Implementation of the Merit-Based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models, CMS-3321-NC, 80 Fed. Reg. 59, 102
October 1, 2015

This was the second comment opportunity CMA provided seeking feedback on issues surrounding the implementation of MACRA.  The first was a very general request for comment in the CY 2016 MPFS rulemaking process.  This opportunity provided a series of very detailed questions surrounding the development of MIPS and APMs.
AMRPA Letter

Other Regulatory Issues

Draft Specifications for the Functional Status Quality Measures for Skilled Nursing Facilities
November 4, 2016
AMRPA Comments

TRICARE; Reimbursement of Long Term Care Hospitals and Inpatient Rehabilitation Facilities
August 31, 2016
AMRPA Letter

Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models  ‚Äč
June 27, 2016

AMRPA responded to the Merit-Based Incentive Payment System and Alternative Payment Model Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models Proposed Rule that was published in the Federal Register on May 9, 2016.
AMRPA Letter

Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2017 Rates; Quality Reporting Requirements for Specific Providers; Graduate Medical Education; Hospital Notification Procedures Applicable to Beneficiaries Receiving Observation Services; and Technical Changes Relating to Costs to Organizations and Medicare Cost Reports
June 17, 2016

AMRPA responded to the Fiscal Year (FY) 2017 Inpatient Prospective Payment System proposed rule that appeared in the Federal Register on April 27.
AMRPA Letter

Fiscal Year 2017 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Proposed Rule  
June 16, 2016

Medicare Prior Authorization of Home Health Services Demonstration
April 5, 2016

AMRPA responded to CMS's recent notice announcing its intention to collect information for a multi-state demonstration program requiring prior authorization of home health services.
AMRPA Letter

Accelerating and Aligning Clinical Episode Payment Models: Elective Joint Replacement; Draft White Paper
March 28, 2016
AMRPA Letter

Accelerating and Aligning Population-Based Payment Models: Financial Benchmarking; Draft White Paper
March 7, 2016
AMRPA Letter

Patient Protection and Affordable Care Act:  HHS Notice of Benefit and Payment Parameters for 2017, Proposed Rule, CMS-9937-P, 80 Fed. Reg. 75,487
December 2, 2015

AMRPA commented on network adequacy rules governing qualified health plans sold in the federally facilitated health exchange marketplaces.  AMRPA provided recommendations as to how CMS should evaluate the adequacy of qualified health plans' coverage of medical rehab services, including ensuring that inpatient rehab facilities comprise these plans' provider networks.
AMRPA Comments

Medicare Program:  Comprehensive Care for Joint Replacement payment Model for Acute Care Hospitals, Furnishing Lower Extremity Joint Replacement Services, CMS=5516-F, 80 Fed. Reg. 73,273
November 24, 2015
AMRPA commented on CMS's list of proposed International Classification of Diseases, 9th revision, Clinical Modification (ICD-9-CM) codes to e used in identifying hip fracture cases in the CJR model.
AMRPA Comments
Medicare and Medicaid Programs:  Revisions to Requirements for Dicharge planning for Hospitals, Critical Access Hospitals, and Home Health Agencies, Proposed Rule, CMS 3317-P. 80 Fed. Reg. 68.125
November 3, 2015

AMRPA Responded to proposed changes to the discharge planning policies required of hospitals, including inpatient rehab facilities, through Medicare's Conditions of Participation, along with more general discharge planning policies that CMS proposed for hospitals and home health agencies.  In addition to recommending that CMS implement most all of its proposed modification to existing discharge planning policies, AMRPA encouraged CMS to adopt a "Post-Acute Care Patients' Rights."
AMRPA Letter

Medicare and Medicaid Programs; Hospital and Critical Access Hospital (CAH) Changes To Promote Innovation, Flexibility, and Improvement in Patient Care
August 15, 2015

AMRPA responded to the proposed rule to update the Medicare Conditions of Participation (CoPs) for hospitals and critical access hospitals (CAHs) to protect patients’ rights and improve patient care that was published in the Federal Register on June 16, 2016.
AMRPA Letter

Legislative Comment Letters

Ways & Means Chairman Kevin Brady (R-TX), Health Subcommittee Chairman Pat Tiberi (R-OH) and Rep. Ron Kind (D-WI), H.R. 3298, the Medicare Post-Acute Care Value-Based Purchasing Act of 2015
September 15, 2016

In response to minor revisions to the PAC VBP legislation, a collection of post-acute stakeholders submitted a joint letter to the bill's sponsors emphasizing the need to let the IMPACT Act run its course, cautioning against drawing resource use comparisons across sites of service, cautioning against geographic resource use comparison and expressing concerns about other specifics aspects of the bill.
AMRPA Letter

Ways & Means Chairman Kevin Brady (R-TX), Health Subcommittee Chairman Pat Tiberi (R-OH), Committee Ranking Member Sander M. Levin (D-MI) and Health Subcommittee Ranking Member Jim McDermott (D-WA), Hearing on the Evolution of Quality in Medicare Part A 
September 7, 2016

AMRPA submitted a statement as part of the Committee Record of the House Ways and Means Health Subcommittee hearing on the Evolution of Quality in Medicare Part A that took place on September 7, 2016. In particular, the comments focused on the Medicare Post-Acute Care Value-Based Purchasing (PAC VBP) Act of 2015, as proposed to be amended (H.R. 3298).
AMRPA Letter

H.R. 4460, The Youth Sports Concussion Act, Rep. Bill Pascrell, Jr. (D-NJ),
June 2, 2016

AMRPA submitted a letter to the House Committee on Energy and Commerce to proceed in marking-up the Youth Sports Concussion Act.
AMRPA Letter

Energy & Commerce Committee and Health Subcommittee Chairmen, Letter to Health Care Community Site-Neutral Stakeholders
February 5, 2016

Chairmen Fred Upton (R-MI) and Joe Pitts (R-PA) solicited comments on a range of site neutral payment proposals focused primarily on hospital outpatient department changes impacted by section 603 of the Bipartisan Budget Act of 2015.  AMRPA stressed the differences between different site neutral payment policies as well as the negative consequences that could result from introducing such policies for post-acute care, where there is a void of evidence to support it.
AMRPA Letter
MedPAC Meeting to Consider Draft Recommendations for Inpatient Rehabilitation Facilities
January 14, 2016

In advance of the MedPAC meeting, AMRPA submitted a comment letter to MedPAC providing detailed information about the variability among IRFs' Medicare margins, questioning some of the Commission's assertions regarding patient selection and coding practices, and encouraging restraint in recommending policies without understanding their potential ramifications.
AMRPA Letter

Senate Finance Committee Chronic Care Working Group, Policy Options Document
December 18, 2015

After reviewing a first round of comment letters, the Senate Chronic Care Working Group released its first work product, which detailed a menu of possible changes for addressing chronic care, particularly Medicare coverage and payment policies.  AMRPA commented about the need to understand the role of post-acute care in treating chronic conditions and reinforce the attention on functional status, as well as other proposals.
AMRPA Letter

Senate Finance Committee Chairman Orrin Hatch (R-UT) and Ranking Member Ron Wyden (D-OR), S. 2368, the Audit & Appeals Fairness, Integrity, and Reforms in Medicare (AFIRM) Act of 2015
December 8, 2015

In advance of introducing the Audit & Appeal Fairness, Integrity, and Reforms in Medicare (AFIRM) Act, Senate Finance Committee staff solicited comments on the discussion draft.  AMRPA used the letter as an opportunikty to express ongoing concerns reference the Recovery Audit Contractors (RACs), highlight positive aspects of the legislation, and suggest additional issues for the Committee's consideration.
AMRPA Letter
Ways & Means Chairman Kevin Brady (R-TX) and Rep. Ron Kind (D-WI), H.R. 3298, the Medicare Post-Acute Care Value-Based Purchasing Act of 2015
July 9, 2015

In response to the introduction of the PAC VBP legislation, a collection of post-acute stakeholders submitted a joint letter to the bill's sponsors emphasizing the need to let the IMPACT Act run its course, cautioning against drawing resource use comparisons across sites of service, and expressing concerns about other specifics aspects of the bill.
AMRPA letter  

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