AMRPA 2024 Policy Priorities

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

Proactive Engagement and Continued Member Support on the CMS IRF Review Choice Demonstration 

• Ensure Transparent & Effective Program Oversight: Maintain continuous engagement with the Centers for Medicare and Medicaid Services (CMS), Center for Program Integrity (CPI), and CMS contractors to ensure consistent and accurate medical reviews of IRF claims and quickly address problematic contractor behavior.   
• Robust Membership & Stakeholder Engagement: Proactively engage with AMRPA members in impacted states, state hospital organizations, and other stakeholder groups to comprehensively monitor developments, hone a consistent stakeholder message on the demonstration, and provide timely operational support for hospitals subject to the demonstration.  
• Push for CMS and Field-Led Program Transparency: Utilize all available avenues to push CMS to publicly and regularly report data on affirmations and denials, including any patient access issues, impacts on referral and admissions patterns, and posture after appeals for denied claims. Support the AMRPA Data Committee’s efforts to collect and track data across the field in order to bolster AMRPA’s advocacy with timely and sophisticated data analysis.  

Navigating Numerous MedPAC Payment Reform Proposals in the Current & Upcoming Cycles 

• Launch Patient-Focused Oppositional Advocacy to Any IRF/Skilled Nursing Facility (SNF) Site-Neutral Payment Proposal or Related Models: Prepare advocacy strategies opposing an IRF/SNF site-neutral payment model (and any general propositions of IRF/SNF “interchangeability”) that are specifically tailored to MedPAC, post-acute care stakeholders, patient groups, and Congress, respectively. 

• Engage in Data-Driven Opportunities to Model and Respond to Proposals and Recommendations for Improving the Accuracy of IRF PPS Payments: Collaborate with AMRPA members and associated IRF data repository experts to produce analytical responses to ongoing IRF payment system proposals. 

Lead Efforts to Ensure Appropriate Oversight and Enforcement of Current Medicare Advantage Coverage Reforms & Continue to Push for Additional Prior Authorization-Focused Relief 

• Comprehensively Respond to New Regulatory Requirements Impacting Prior Authorization and MA Plan Practices to Ensure Maximum Monitoring, Compliance, & Enforcement.  
• Identify Additional Policy Reforms Needed to Meaningfully Improve Access to IRF Care in MA and Advocate for Changes through Legislation, Regulation, and Sub-Regulatory Guidance, as Appropriate.    
• Continue Strong Partnerships with Post-Acute Care Organizations and Other Stakeholders to Clarify and Enhance new Medicare Advantage Utilization Management Requirements and Build on Legislative and Regulatory Progress in Recent Years.  
• Identify and Develop Opportunities to Enhance Public Awareness of the Burdens of Prior Authorization and Other MA Plan Practices on Patients and Providers in Rehabilitation Settings.    

Evaluate and Engage in Opportunities to Limit the Negative Impacts of Expanding Quality Reporting Program (QRP) Requirements 

• Alleviate Administrative Burden and Payment Penalties Through Review and Removal of Existing IRF QRP Measures: Prepare advocacy strategies recommending removal of certain IRF QRP measures that are either “topped-out” or do not provide value when compared to their respective administrative burden. 

• Reduce or Eliminate the Risk of IRF QRP 2% Payment Penalties for Good Faith Reporting: Through planning, education, and legislative action, limit or eliminate reductions in IRF payment resulting from overly stringent IRF QRP requirements. 

Identify or Develop an IRF Patient Experience or Patient Satisfaction Measure 

• Address Requests from MedPAC and CMS to Include a Patient Experience or Patient Satisfaction Measure as a Quality Measure or Outcome: Through review of existing measures or development of a new measure, AMRPA will work to recommend a Patient Experience or Patient Satisfaction Measure‎ to CMS and MedPAC. 

Strategic Engagement with the OIG as the Pending Follow-Up National IRF Audit Takes Shape 

• Continue Multi-Faceted Engagement with the OIG with the Goal of Addressing Deficiencies in the Most Recent National IRF Audit: Given the negative implications of the 2018 national IRF audit (including being the likely impetus for the Review Choice Demonstration and heightened MedPAC scrutiny), the 2024/2025 follow-up audit presents an opportunity to address numerous sampling and medical review-related issues identified by AMRPA and other stakeholders. A positive audit outcome could also provide compelling arguments against the continuation of the RCD and other oversight programs. 

Continue Advancing AMRPA Presence and Awareness on Capitol Hill: Given the challenges in the congressional environment for passing legislation due to the closely divided control in each chamber, the election year impact on the legislative process, and ongoing pressures to cut costs and limit overall spending, AMRPA will explore different paths to bolster the association’s and field’s support and relationships in Congress and position ourselves more strongly for future years. 

Rejuvenate AMRPA’s Rehabilitation Research Agenda  

• Identify Opportunities to Support a Robust Rehabilitation Research Portfolio by Federal Agencies, Academia, and the Private Sector: While AMRPA has generally been focused on Association-initiated research projects in recent years, there is a growing interest in broadening the scope of AMRPA’s research efforts and partnership with other entities in the rehabilitation research field. 

Develop Strategies to Address Rehabilitation Workforce Issues 

• Launch Dedicated AMRPA Effort to Develop and Implement Strategies to Address Ongoing Workforce Issues Impacting IRFs.  
• Collaborate with Industry Stakeholders to Understand Major Drivers of Workforce Shortages and Identify Consensus Solutions.  

Enhance the Value of IRF Care Through Continued Collaboration and Refinement of Rehabilitation Rankings 

• Maximize Communication and Collaboration Opportunities with U.S. News & World Report to Enhance Value of Rehabilitation Rankings.  
• Review and Consider Collaboration with Other Organizations that Provide Rankings for IRFs, such as Newsweek or Leapfrog, among Others.  

February 14, 2024