fah hospital policy blog

Perspectives on health policy affecting America’s hospitals and the patients we serve.

Category Archives: rehabilitation-care

FAH Suggests Improvements to Extreme and Uncontrollable Circumstances Policy

January 30, 2018 | FAH Policy Blog Team

Category: Medicare, Rehabilitation Care

In a letter sent today to CMS Administrator Seem Verma, FAH expressed appreciation for the new Extreme and Uncontrollable Circumstances policy for the Comprehensive Care for Joint Replacement (CJR) Model, which provides relief to the hospitals affected by this year’s disasters.

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FAH Urges MedPAC Not to Recommend Site-Neutral Payment Policies

December 18, 2014 | FAH Hospital Policy Blog Team

Category: Medicare, Rehabilitation Care

The Federation of American Hospitals submitted a letter to the Medicare Payment Advisory Commission (MedPAC) today, urging the group to stop considering site-neutral payment policy recommendations for inpatient rehabilitation facilities (IRFs) and skilled nursing facilities (SNFs). The implementation of these policies on payment systems could ultimately lead to the opposite of the intended outcome: poorer patient care.

Several problems are associated with the potential payment policy recommendation, which the FAH letter outlines:

There is a lack of reliable clinical evidence and quality data. The Urban Institute study heavily relied upon by MedPAC has serious data flaws and limitations. A recent Dobson study comparing the effectiveness of IRF and SNF care has alternatively found better outcomes for patients in IRFs.

It is premature to implement site neutral payment policies until uniform assessment instruments, called for in the recently enacted Medicare Post-Acute Care Transformation (IMPACT) Act, are developed and ready to use.

Blunt site-neutral payment policies, without risk and case-mix adjustment as well as conforming regulatory change, risk placement of beneficiaries in clinically inappropriate settings.

The FAH shares MedPAC’s goals of making care more efficient and effective, with higher quality and better patient outcomes for Medicare beneficiaries, as well as a more patient-centered approach. However, site-neutral payment policies should be used very carefully and not in the absence of clear and reliable clinical data, which does not now exist.

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Senator Mark Kirk Stands Up for Rehabilitation Hospitals & the 60% Rule

November 21, 2013 | FAH Hospital Policy Blog

Category: Rehabilitation Care

Senator Mark Kirk (R-IL) penned an op-ed in The Hill this week, offering vociferous support for rehabilitation hospitals and calling for the preservation of the 60% rule. Kirk, who suffered a stroke in January 2012 returning to the Senate this year, touches upon his own experience with rehabilitation to highlight the critical care patients can only receive at an inpatient rehabilitative facility, or IRF.

“I credit returning to the Senate to nearly a year of intense, grueling physical and occupational therapy. It is now a major priority for me to help others who suffer from major health events to get back to work through rehab, and I believe access to specialized care at a rehabilitation hospital holds the key to meeting this goal.”

In the editorial, Kirk outlines the ongoing battle in Congress regarding the 60% rule, which would severely impact access to rehabilitation care for those who fall outside of the parameters of specific Medicare prerequisites. Kirk explains,

“This would be a mistake. Under the proposed change, some hospitals will close, and children managing cancer treatments or adults needing rehab after organ transplants will be turned away. A person who has survived a catastrophic infection or a complicated hospital stay but does not have the basic strength or endurance for mobility would also be turned away.”

IRFs offer specialized care that patients cannot receive in a hospital, nursing home or other facility. And as Kirk points out, numerous studies prove rehabilitative care is a more efficient and cost-effective means to help patients rebound and return to their normal lives. Kirk agrees with the sentiments of organizations like FAH, MedPac and CMS, who have already recommended maintaining the 60% rule as it stands today, adding,

“It doesn’t make sense to change the rule when the current framework helps individuals of all ages return to their productive place in society with the right remedies. We shouldn’t be holding patients back with options for lesser care, or worse, no options at all. Over the long run, changing the rule will only push people into reduced care, driving up costs and preventing them from returning to work faster.”

The FAH is glad to have the support of Senator Mark Kirk in our efforts to preserve the 60% rule so that all patients who require inpatient rehabilitative care can get the proper treatment they deserve. Senator Kirk is an example of the extraordinary improvement patients can experience with excellent rehabilitative care. That is the standard every American should have access to, should they ever need it. The FAH encouraged Senator Kirk’s colleagues on the Hill to support his efforts and stand with him in preserving access to IRFs.

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FAH Supports Responsible Approaches to PAC Policies

September 06, 2013 | FAH Hospital Policy Blog

Category: Medicare, Rehabilitation Care

Last week, the Federation of American Hospitals submitted comments to the leadership of the House Ways and Means Committee and its Health Subcommittee on the President’s proposed post-acute care (PAC) policies in its Fiscal Year 2014 budget. In this letter FAH advocates for responsible approaches that not only preserve current PAC capacity, but also support continuing improvements in patient care through close collaboration between providers and lawmakers. The core policies outlined in the FAH letter include:

No further cuts. When cuts are made to PAC providers’ already limited resources it inhibits access to PAC services at the same time as demand is increasing with an aging Medicare population. Specialized PAC providers like inpatient rehabilitation facilities (IRFs) and long-term care hospitals (LTCHs) treat patients with severe and medically complex cases whose medical and therapy care result in higher costs. Because of already existing financial pressures on PAC facilities, it is crucial that they are not further impacted by arbitrary cuts.

Right care, right place, right time. One of the goals of the FAH is ensuring patients receive the right care at the right time and in the right setting. The proposed site-neutral payment policies would significantly underestimate the differences between patient populations served in IRF and skilled nursing facilities (SNF) settings. These policies would jeopardize patients’ access to medical rehabilitation and provide a disservice to the most severely compromised patients by ignoring the differential cost structures and regulatory requirements between different types of PAC facilities.

Maintain the 60% rule. In order to be considered an IRF for Medicare reimbursement purposes, 60% of a facility’s patients must have a qualifying condition. The proposal to increase this threshold to 75% would impose further restrictions on the number and types of patients that can be admitted to IRFs. This in turn jeopardizes patients’ access to the care they need and will instead shift patients to facilities that do not meet their needs.

Handle (bundling) with Care. If carefully planned, payment bundling could empower providers to further integrate delivery of care. However, there are significant challenges in implementation, and the bundling options have not been fully evaluated. A premature transition to bundled payments would force providers and policymakers to implement a policy without the information necessary to create a well-designed plan.

FAH is grateful for the opportunity to weigh in on this critical care issue and advocate on behalf of patients and patient access to quality care. In addition to this most recent letter, FAH has previously commented on this subject to other committees in the House and Senate. Last week FAH President and CEO Chip Kahn submitted a letter to the Senate Finance and House Ways and Means Committee Leadership and, earlier in August, The Federation of American Hospitals submitted a letter to Congressman Dave Camp.

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