AMRPA 2023 Policy Priorities

AMRPA has developed the following policy agenda to protect patient access to timely, necessary, and high-quality inpatient rehabilitation care:

• Proactive outreach and preparation for the CMS Review Choice Demonstration
  • Enhance relationships with state hospital groups in demonstration states to ensure consistent and accurate medical reviews of IRF claims and protect access to inpatient rehabilitation care.
  • Engage in continuous discussions with CMS, Center for Program Integrity (CPI) and CMS contractors to improve CMS audit processes, ensure consistent and accurate medical reviews of IRF claims,‎ and flag problematic contractor behavior as efficiently as possible to protect inpatient rehabilitation hospitals from unnecessary administrative burden. 
  • Develop and support efforts to achieve real time data collection on patient access issues, referral changes, and denials for CMS and oversight entity awareness.
     
• Advance Prior Authorization Reform
  • Develop comprehensive response to CMS prior authorization proposals and engage with the CMS team to convey the IRF-specific perspective.
  • Enhance focus on plan transparency requirements and the public reporting of prior authorization determinations, appeals, and overturn rates.
  • Continue collaboration with other stakeholders to reform Medicare Advantage prior authorization policies and practices to ‎improve patients’ access to medically appropriate post-acute care without ‎arbitrary denials and/or unnecessary delays.‎
     
• Maximize engagement on the Pending Office of Inspector General (OIG) IRF Audit Report
  • Development and coordination of response to OIG process and determinations.
  • Educate auditors and regulators to effectively address any misconceptions between medical necessity and technical denials.
  • Utilize the OIG results to improve the review and audit processes through collaboration and discussion with industry stakeholders.
     
• Address IRF Quality Reporting Program (QRP) Compliance Issues & Reduce Reporting Burdens
  • Engage with CMS to revise IRF-PAI guidance and reduce Quality Reporting Program payment penalties through improved education and reporting clarifications.
  • Advocate for legislative changes to reduce IRF-PAI compliance thresholds and QRP payment penalties.
  • Seek removal of topped-out or irrelevant quality measures and IRF-PAI data elements that are not used for payment or quality purposes.
  • Request that CMS provide relief for unnecessary administrative burden created by the continued expansion of IRF-PAI data collection for measures that are untested, unproven, and not endorsed.
     
• Enhance and improve engagement with MedPAC
  • Execute site visits to create understanding of the value of IRF services and alternatives to across-the-board payment reductions.
  • Nominate a rehabilitation champion to the MedPAC Commission and better engage with current Commissioners with ties to the field.
  • Respond to and educate MedPAC staff and commissioners on the differences between the level of care provided at IRFs and other settings.
     
• Strategically respond to Unified Post-Acute Care Payment System efforts
  • Launch Future of PAC Reform Workgroup to lead AMRPA response to ongoing MedPAC and CMS/RTI prototype development efforts.
  • Plan and execute Congressional outreach with focus on potential impacts to patients and access to hospital-level care.
  • Advocate for the importance of pre-implementation testing for any payment system prototype.
     
• Develop strategies to address workforce issues
  • Launch Workforce Workgroup to develop and lead strategies to address ongoing workforce issues impacting IRFs.
  • Collaborate with industry stakeholders to convey IRF-specific labor issues.
  • Assess engagement with HRSA to expand educational or grant opportunities.

March 13, 2023