2018 Key Policy and Operational Accomplishments
AMRPA has continued to be the leading policy voice in Washington D.C. for inpatient rehabilitation. Through our efforts, we have maintained a constructive relationship with key policymakers in Congress and the Trump Administration. In Congress, AMRPA has been well served by a consistent messaging campaign to remind members of Congress of the importance of rehabilitation to their constituents. AMRPA’s multiple meetings with the Department of Health and Human Services (HHS), the Centers for Medicare and Medicaid Services (CMS) and other senior Administration officials have made clear the need for regulatory relief and the value rehabilitation brings to Medicare and other federal health programs.
Highlights of these efforts include the following:
- Maintained and developed important relationships with Congressional leaders to convey the importance of medical rehabilitation 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.
- Held multiple meetings with key Trump Administration and career officials in HHS, CMS and the White House Budget Office to convey the need for regulatory relief and equitable payment policies for rehabilitation hospitals and units. This included discussions about the need to reign in CMS contractors and their auditing practices, the improper use of prior authorization by Medicare Advantage plans, and many other topics.
- Took an active role in the Therapy Cap Repeal coalition, which was ultimately successful in obtaining a permanent repeal of the outpatient therapy cap in the Bipartisan Budget Act of 2018 which had been in statute for nearly 20 years. The law also includes several payment reductions for the PAC sector, but IRFS were not subjected to any negative payment reforms.
- Engaged with key Members of the House Ways and Means Committee on its Red Tape Relief initiative by providing the Committee with specific recommendations on how to reduce regulatory burdens on rehab hospitals. Additionally, AMRPA Board Chair Rich Kathrins participated in the Committee’s roundtable discussion on post-acute care. The Committee recommended recurring IRF-specific Open Door Forums (ODFs) in a letter to the CMS Administrator. AMRPA, among other priorities, advocated for relief from the 60% Rule and the 3-hour Rule restrictive therapy requirements.
- Through extensive member engagement, provided thorough responses to CMS proposals to change the IRF PPS and related rehabilitation hospital regulations, such as measures being developed for the IRF Quality Reporting Program. AMRPA also provided rehabilitation-focused responses to CMS proposals to update the Physician Fee Schedule, Quality Payment Program, long-term care hospital (LTCH) and acute care hospital payment systems, the home health pre-claim review demonstration, and HHS’ Request for Information on health care innovation.
- Provided multiple written responses to the Medicare Payment Advisory Commission (MedPAC) on its evaluations of post-acute care payments.
- AMRPA weighed in on the importance of including access to rehabilitation in advanced payment models, including providing responses to CMS proposals regarding the Bundled Payment for Care Improvement Advanced (BPCI-Advanced) model and the Shared Savings Program Accountable Care Organizations (ACOs).
- Attracted national-profile speakers to AMRPA’s Leadership Forum, including Presidential Cabinet members, key Congressional staff, and other senior health care officials, 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.
- Engaged in persistent efforts to fend off burdensome and unnecessary audits of IRF Medicare claims, including meeting with CMS staff on multiple occasions on a variety of topics relating to inappropriate behavior of Medicare contractors.
- Weighed in through formal comments on the Administration’s proposal to modernize the Stark Self-Referral and Anti-Kickback Regulations to permit more value-based care delivery initiatives.
- Hosted a Medical Directors Summit with 47 physician attendees, which covered topics from implementing a specialty rehabilitation program to complying with Medicare documentation requirements.
- Held the 16th Annual AMRPA Educational Conference and Expo in Boston, MA and debuted AMRPA’s 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.
- Held the AMRPA Spring Leadership Forum and Congressional Fly-In, which featured two breakout programs: the Rehabilitation Administrators’ Workshop and the Medical Directors Symposium.
- Live and Recorded Webinars
- Marketing the Mary Way: Digital Style
- IRF Rules and Regulations 102: For New and Seasoned IRF Leaders
- Accessing Return to Acute Care for Program Improvement
- Audits and Appeals
- Utilizing FIM Scores to Establish Fall Risk on an Inpatient Rehabilitation Unit
- Outside of Acute Care Hospitals, Where Do Our Referrals Come From?
- Specialized Medical Home: Innovative Healthcare for Patients with Spinal Cord Injury
- New 2018 CARF Standards: Workforce Development and Management
- Leveraging Community Relationships to Enhance Rehabilitative Services
- Transforming Post-Acute Care Strategies for Optimal Success in Bundled Payment
- Medicare Guidelines for Inpatient Rehabilitation Facilities: Both Sides of the Fence
- Important Updates in the IRF Quality Reporting Program
- On Demand Webinars
- Members-only access to recorded webinars from 2013-2017
- Free Members-Only Webinars
- Periodic updates on Congressional and Regulatory Developments
- FY 2019 IRF PPS Proposed Rule
- FY 2019 IRF PPS Final Rule
Newly Redesigned AMRPA Website
- Member Portal (My AMRPA)
- Allows the primary contact of organizations to add and remove individuals from their organization’s account.
- Allows members to view and pay their open invoices online.
- Allows members to view their purchased webinar recordings and complete webinar evaluations to claim CE credit.
- Find A Provider Feature
- Allows the public to locate AMRPA member hospitals in their area.
- Engage AMRPA
- A community platform, enabling a private social network for members to form communities, collaborate, manage industry profiles, and connect with peers and colleagues.
- Recorded webinars, issues of the AMRPA magazine, recordings of Members-Only calls are all available for view or purchase.
- Career Center
- Allows members to post resumes or look for jobs in the medical rehailitation field at a discounted price.
- 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.
- 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® innovative Outcomes Reports provide powerful national and regional comparative performance data and are updated nightly for timely and effective decision support.
- eRehabData’s® comprehensive quality reporting completion checks help your facility maintain compliance with the Centers for Medicare and Medicaid Services’ (CMS) Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) reporting requirements. Our real-time IRF QRP completion override report identifies those assessments with incomplete data to help you avoid a 2 percent payment reduction from CMS due to non-compliance with the IRF QRP reporting requirements.
- 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. Our 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® 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.
Looking ahead, 2019 promises to present new legislative and regulatory challenges in the aftermath of the mid-term elections and the new 116th Congress, including a large budget deficit that Congress likely will need to address. Your continued AMRPA membership is valued and appreciated.