2019 Key Policy and Operational Accomplishments
In 2019, AMRPA continued to zealously advocate for the inpatient rehabilitation industry in Washington, D.C. AMRPA launched a number of new policy and operational initiatives and scored a number of victories for members through robust engagement with the Administration and Congressional leaders. In Congress, AMRPA has advocated for changes to coverage and reimbursement policies in order to ensure patient access to inpatient rehabilitation, and has worked actively to advance a number of bills that align with AMRPA’s legislative agenda. Furthermore, as AMRPA’s membership grows, AMRPA continually identifies and fosters Congressional relationships that correlate with our expanding national presence, which will ensure that AMRPA continues to be the leading policy voice for inpatient rehabilitation. On the regulatory side, AMRPA engaged extensively with the Department of Health and Human Services (HHS), the Centers for Medicare and Medicaid Services (CMS) and other senior Administration officials in efforts to both champion AMRPA’s regulatory priorities – such as regulatory relief from burdensome Medicare rules – as well as successfully oppose potential policy threats, such as reimbursement cuts. AMRPA will continue these and other efforts as the post-acute care landscape continues to rapidly evolve in 2020 and beyond.
Highlights of these efforts include the following:
- Held multiple meetings with key Trump Administration and career officials in HHS, CMS and the White House Budget Office to strongly – and successfully – oppose a provision in the FY 2020 Budget that would have adversely affected patient access to inpatient rehabilitation hospitals and units. Through this advocacy, AMRPA was also able to score several significant regulatory policy victories, including a positive payment update in the FY 2020 inpatient rehabilitation facility payment system rule, the inclusion of inpatient rehabilitation facilities in acute hospitals’ discharge plans, and the adoption of the concurrent year’s IPPS wage index in the inpatient rehabilitation facility payment system ( which AMRPA has long advocated as the more accurate, timely wage index)
- Provided a comprehensive response to CMS’ Patients over Paperwork Request for Information (RFI) and used the RFI as an opportunity to engage CMS on a number of regulatory burdens facing the inpatient rehabilitation industry. Key priorities highlighted in AMRPA’s comments included relief from the 60% Rule and the 3-hour Rule restrictive therapy requirements, patient access issues created by prior authorization policies in Medicare Advantage, burden reduction from quality reporting requirements, and the need for new regulatory flexibilities to allow IRFs to meaningfully participate in alternative payment models.
- Engaged extensively with CMS in response to the proposed FY 2020 IRF PPS and related rehabilitation hospital regulations. AMRPA engaged with key agency officials and submitted two comment letters addressing members’ questions and concerns with numerous provisions in the proposed rule. AMRPA successfully advocated for the adoption of numerous provisions in the final FY 2020 IRF PPS, including a positive payment update and the delay of all-payer reporting in the IRF Quality Reporting Program (QRP).
- In addition to responding to the IRF PPS rule, AMRPA also advocated for industry-focused changes in response to CMS’ proposed Physician Fee Schedule and Quality Payment Program rule, and inpatient prospective payment system (IPPS) rule. Furthermore, AMRPA advocated in strong opposition to a provision in the outpatient prospective payment system requiring hospitals – including IRFs – to publicly post payer-negotiated rates for certain services.
- Launched a comprehensive response to a 2018 Office of Inspector General (OIG) report on IRF compliance with Medicare coverage criteria, including a meeting with key OIG officials involved in the report. AMRPA has continued to engage with the OIG throughout 2019 and will be undertaking a review of certain files included in the report with the goal of improving the effectiveness and advocacy of future IRF audits
- Actively engaged with the CMS/RTI Unified PAC PPS Technical Expert Panel (TEP) and submitted comments in February 2019; will participate in the upcoming November 2019 TEP
- Successfully nominated an AMRPA member to serve as a panelist on the HHS Quality Summit, an initiative designed to help shape future CMS quality policies
- Promptly identified the omission of inpatient rehabilitation facilities from key sections of the “Medicare: What’s Covered App” and engaged with relevant CMS leaders to ensure IRFs were correctly displayed and listed for beneficiaries
- Represented the interests of the industry through the submission of numerous comprehensive comment letters, including formal comments on CMS’ draft guidance regarding hospital co-location and CMS’ proposed rule related to interoperability issues, among others.
- Maintained and developed important relationships with Congressional leaders to provide education about the value of inpatient rehabilitation and convey the importance of the industry for the communities they represent. AMRPA’s annual Congressional fly-in totaled over 60 Congressional office meetings. AMRPA members also held multiple additional meetings with Congressional offices throughout the year to advocate for a range of issues, such as Medicare Advantage coverage reforms, AMRPA’s priorities for alternative payment models (APMs), and the importance of certain forms of regulatory relief, such as the three-hour rule, among numerous others.
- Following robust Congressional advocacy on the need to address prior authorization reforms in Medicare Advantage, AMRPA joined 300+ organizations in supporting legislation (H.R. 3107, the Improving Seniors’ Timely Access to Care Act) that would improve several of the most problematic aspects of prior authorization. AMRPA has and continues to champion specific changes to the bill such that it would most effectively address the most pressing problems that prior authorization presents to the inpatient rehabilitation industry
- Provided members with written reports from every Medicare Payment Advisory Commission (MedPAC) session – the Congressional advisory body on Medicare issues - that touched on the unified PAC PPS and/or had implications for the inpatient rehabilitation industry
- Convened an in-person meeting with MedPAC leadership and staff to discuss AMRPA’s concerns with MedPAC’s recommendations related to a unified PAC PPS and advocate for the importance of adequate IRF reimbursement and patient access.
- Responded to a Congressional RFI regarding potential legislative opportunities to expand the utilization of telehealth, and engaged in follow-up discussions with relevant Congressional Members’ offices regarding updates to the legislative text.
Other Efforts to Promote the Inpatient Rehabilitation Industry
- Organized discussion with AMRPA leadership and U.S. News and World Report team (including RTI) to discuss the new U.S. News’ ranking methodology for rehabilitation hospitals, allowing AMRPA to make recommendations on the type of data to be included in the methodology and the weights given to such data to produce an objective and accurate ranking system. U.S. News stated interest in continuing to engage with AMRPA in its work as the methodology is developed throughout 2019-2020
- Participated in a long-term project with four other PAC associations representing skilled nursing facilities (SNFs), long-term care hospitals (LTCHs) and home health agencies (HHAs) focused on key priorities and considerations for future alternative payment models (APMs). The project culminated with AMRPA getting the opportunity to outline its association-specific recommendations and concerns on future APMs directly to CMMI officials.
- Attracted national-profile speakers to AMRPA’s Leadership Forum, including Presidential Cabinet members, key Congressional and CMS staff, the Center for Medicare and Medicaid Innovation (CMMI) director, among others.
- Supported and actively participated in key rehabilitation advocacy coalitions, including the Coalition to Preserve Rehabilitation (CPR), Consortium for Citizens with Disabilities (CCD), Independence Through Enhancement of Medicare and Medicaid (ITEM) Coalition, the Fund for Access to Inpatient Rehabilitation (FAIR Fund), and several others. Participated in events sponsored by other key PAC stakeholders, including the National Association of Long Term Hospitals (NALTH) and the National Association of Rehabilitation Providers and Agencies (NARA)
- Hosted a Medical Directors Symposium with 63 physician attendees, which covered topics from implementing a specialty rehabilitation program to complying with Medicare documentation requirements.
- Hosted the 17th Annual AMRPA Educational Conference and Expo in San Diego, CA including an extended full-day pre-conference IRF Boot Camp. The Boot Camp provided Rehab Managers and Medical Directors of Inpatient Rehab Programs with fundamental knowledge on key rules and regulations that govern Inpatient Rehab Programs.
- Hosted the AMRPA Spring Leadership Forum and Congressional Fly-In, featuring the Medical Directors Symposium, opportunities to hear from regulatory officials, and visits to congressional offices.
- Hosted the renewed AMRPA Regional Meeting Series in Grand Rapids, MI and Jacksonville, FL, offering networking and learning opportunities at the local level.
- Live and Recorded Webinars
- Continuing Care Networks: The Importance of Post-Acute Integration
- Understanding your Position for FY 2020 and the New CMGs
- Medical Rehabilitation Headlines and Highlights
- New Nurse Leader Orientation
- Maximizing Admission Processes to Drive Bottom-Line Results
- Road to Recovery: The Intersection Between Patient Experience and Patient Education
- Implications of the IRF OIG Audit and Best Practices for Avoiding a Similar Fate
- Recruitment to Retention
- Stepping it Up: Improving Your Amputee Rehabilitation Program
- Considerations for Adolescents on Adult Inpatient Rehabilitation Units
- What Does My Spinal Cord Injury Patient Need?
- Arrangements with Physicians and Other Risks: What You Don’t Know Can Hurt You
- On Demand Webinars
- Members-only access to recorded webinars from 2013-2018
- Free Members-Only Webinars
- Periodic updates on Congressional and Regulatory Developments
- FY 2020 IRF PPS Proposed Rule
- FY 2020 IRF PPS Final Rule
- AMRPA keeps members informed of all significant policy, legislative and regulatory issues affecting medical rehabilitation providers through:
- Off the Record: an electronic weekly newsletter, which includes up to date summary information on legislative and regulatory issues affecting Medical Rehabilitation providers.
- Grassroots Action Alerts: timely electronic alerts to AMRPA members designed to mobilize national member responses to critical issues requiring Congressional action.
- AMRPA Magazine: monthly report on medical rehabilitation matters and trends, including in-depth analysis of legislative, regulatory, research, and operational issues. All issues are available online, free of charge to members.
PAC Market Analysis Reports
- Using the most recent two years of available Medicare claims data, Dobson DaVanzo & Associates is delivering inpatient rehabilitation providers with market-level information on episode spending and key performance metrics across all Medicare discharges.
- The reports also include information on episode spending and key performance metrics on Medicare’s Bundled Payment for Care Improvement (BPCI) Initiative and Comprehensive Care for Joint Replacement (CJR) model in providers’ respective areas.
- The analysis helps inpatient rehabilitation providers understand:
- How acute care hospital referral patterns and other post-acute care providers are affecting the market.
- How your facility’s episode spending and key performance measures compare with state and national IRF benchmarks (wage index-adjusted).
- How the BPCI and CJR models are impacting the markets.
- eRehabData’s® new suite of tools that model the impact of the new CMG rules enables rehabilitation hospitals to mitigate a potential deleterious effect on Medicare reimbursement.
- eRehabData’s® newly launched IRF QRP Certification Exam system helps hospitals gauge staff proficiency with scoring subsets of the IRF Quality Reporting Program items on the IRF-PAI and determine where education is required in the wake of major regulatory changes. AMRPA/eRehabData® QRP Certification status is available to users meeting or exceeding the threshold score.
- eRehabData’s® built-in electronic Pre-Admission Screening (PAS) Tool provides comprehensive and compliant pre-admission screenings. Features such as physician notification, mobile device approval, and offline screenings support efficient coordination between all members of the admission team. Data from the PAS Tool feed into the real-time Referrals Outcomes reports, offering information on referral and admission trends and patterns as they unfold.
- eRehabData’s® sophisticated 60% Rule compliance reports predict both presumptive and conditional compliance using multiple risk models and always reflect the latest updates in CMS’ rules. The 60% Rule Compliance Report provides real-time calculations on your facility’s compliance status for various payer groups and compliance methodologies.
- eRehabData’s® Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI) is built on a three-tiered system of data integrity checks that conforms to CMS’ requirements. eRehabData® also performs real-time analysis of your facility’s IRF-PAI data to support assessment coding and scoring best practices.
- eRehabData’s® comprehensive QRP data collection completion checks and live reports help facilities conform to data submission threshold requirements and avoid reimbursement penalties.
- eRehabData® is owned by AMRPA, which utilizes eRehabData’s® statistical analysis and policy models based on aggregated data to inform the association’s legislative and regulatory advocacy efforts on behalf of the medical rehabilitation industry.
- eRehabData’s® friendly and responsive customer support is available via email, phone, and built-in system messaging to answer your questions from compliance to coding to software.
2020 promises to present new legislative and regulatory challenges as Congress braces for the upcoming November elections and regulatory agencies continue their work on a unified post-acute care payment system and the testing of new payment and coverage models.