Medicare Advantage and Prior Authorization Resources

As the Medicare Advantage (MA) program continues to grow, with more than half of eligible beneficiaries enrolled in MA as of 2024, AMRPA is committed to ensuring that all patients, regardless of their choice of payer, have robust access to medically necessary inpatient rehabilitation care. AMRPA prioritizes engagement with federal policymakers and health plans to ensure appropriate enforcement and oversight of the program, and to minimize the burden of prior authorization and other MA plan practices on patients and providers in the rehabilitation setting.  

For questions regarding the MA program, prior authorization, or other issues of access to IRF care, please contact AMRPA staff. We also welcome reports from the field about plan denials, prior authorization burdens, and other current trends to inform our advocacy efforts.  

Below, please find important information on current Medicare Advantage regulations and AMRPA resources to assist hospitals, clinicians, and patients. Read AMRPA’s recent public comments on MA issues here. 

Submit Your Data for AMRPA’s Summer 2024 Prior Authorization Survey!  

CMS Request for Public Comment: Service-Level Data Collection for Initial Determinations and Appeals (Comments due Oct. 8, 2024) 

CMS Request for Public Comment: Medicare Part C Utilization Management Annual Submission and Audit Protocol Data Request (Comments due Nov. 12, 2024) 

Recent Rules: 

2025 Medicare Advantage Final Rule (effective January 1, 2025) 

2024 Medicare Advantage Final Rule (effective January 1, 2024) 

CMS Medicare Advantage Guidance 

In 2021, AMRPA conducted a field-wide survey on Access to Inpatient Rehabilitation Care for Medicare Advantage Beneficiaries: An Examination of Prior Authorization Practices. This survey reflected data from 475 freestanding IRFs and IRF units and was an essential advocacy tool spurring additional CMS and Congressional action to reform prior authorization and other MA plan practices. For more information on our 2021 survey and the full published results, visit our 2021 Prior Authorization Survey homepage.  

For 2024, AMRPA is in the process of conducting a new prior authorization survey to collected updated data on the impact of new policies on MA plan practices. For more information on our 2024 survey efforts, and to learn how to submit your hospital’s data, visit our 2024 Prior Authorization Survey homepage.  

Effective January 1, 2024, Medicare Advantage (MA) plans must follow a new set of regulations when assessing medical necessity and documentation of IRF admissions, usually in the context of prior authorization. When denials of IRF admissions through prior authorization occur, a peer-to-peer consultation between the MA plan and the IRF physician/clinician often takes place. In these instances, a Q&A created by the FAIR Fund in coordination with AMRPA should be used to assist IRF physicians and clinicians in challenging the rationale for the MA plan’s denial. This Q&A operationalizes new regulations applicable to MA prior authorization denials of all types of care, but it is tailored to IRF denials. AMRPA and FAIR Fund recommend that the IRF physicians cite chapter and verse of the regulations themselves in their face-to-face discussions with MA plans, which will put them on notice that the IRF physician/clinician is well informed of the new requirements.  

Members: Log in to download the Q&A.

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