fah hospital policy blog

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

Category Archives: rehabilitation-care

FAH Submits Letter to Senate Finance, House Ways and Means Committee Leadership Regarding Post-Acute

August 28, 2013 | FAH Hospital Policy Blog

Category: Medicare, Rehabilitation Care

Late last week, FAH President and CEO Chip Kahn submitted a letter to Senators Baucus and Hatch and Representatives Camp and Levin, the respective Chairmen and Ranking Members of the Senate Finance and House Ways and Means Committees. The letter is an opportunity for the FAH to offer comment on the efforts of both Committees to foster Medicare post-acute care (PAC) reform.

In the letter, FAH expresses support for the Committees’ efforts to reform PAC, outlining a number of critical and feasible means by which to do so. FAH remains committed to improving access to and quality of post-acute care.

In the letter, however, Kahn notes:

“We recognize that moving forward, implementing these policies and demonstrating their efficacy will be difficult, and, as such, recommend a measured approach to payment and delivery system reform with realistic expectations.”

Kahn also cautions against a series of payment reforms and cuts in his letter, especially further cuts to fee for service payments. As we have noted in previous blogs, hospitals have faced $95 billion in cuts over the last 3 years alone. Further cuts will inhibit the ability of hospitals to achieve the very goals these Committees have set.

PAC reforms must also take into consideration the current trend of historic cost-savings the U.S. is experiencing in both Medicare and overall health care spending. Many recent studies (including that of Dobson DaVanzo commissioned by FAH) have concluded that this fortuitous spending slowdown is largely due to structural reforms in care. Hospitals are proud to have implemented several structural reforms that have aided the trend and helped ensure access to quality care for Americans nationwide.

In the letter, the FAH applauds the Committees for recognizing the important role that post-acute providers currently play in improving quality of care, patient outcomes, and increased efficiency in the Medicare program. Any reforms to post-acute care must ensure these goals are continuing to be met and access to post-acute care will be maintained for the millions of Americans who need it.

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Rehabilitation at Recess: What Is Your Member of Congress Doing to Protect Access to Rehabilitation

August 08, 2013 | FAH Hospital Policy Blog

Category: Rehabilitation Care

As Members of Congress are returning home to their districts for the August recess, they will spend much time focusing on those issues that matter most to constituents. For many Americans, ensuring continued access to high quality rehabilitation care is a top priority. As we noted in an earlier post, rehabilitation hospitals or inpatient rehabilitation facilities (IRFs) are often the most appropriate treatment location for patients recovering from serious ailments like a stroke or heart attack. Rehab hospitals are the place where intensive therapies are administered by skilled health professionals so that patients are able to return to their everyday lives as soon as possible.

Some in Washington want to cut rehabilitation services. This would have a significant and detrimental impact on patient care. Fortunately, IRFs have received much attention here in Washington; just last month, 83 Members signed a letter to HHS Secretary Sebelius.

As Members of Congress spend time in their districts, speaking with constituents and visiting care facilities, we encourage them to visit their local rehabilitation hospital, see the important work being done, and join their 83 colleagues in supporting this critical and unique pillar of care for patients nationwide.

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A Note to Congressional Members Before Recess

August 05, 2013 | FAH Hospital Policy Blog

Category: Rehabilitation Care, Rural, Spending Slowdown

As Congress begins its annual August recess, FAH would like to take time out to once again thank and highlight those members who have supported their local hospitals by sponsoring and cosponsoring important legislation, called hearings, and shined a light on the health care issues critical to preserving patients’ access to care. These efforts recognize the important health and economic role that hospitals play in their local communities. Two prime examples of this are the case of rural and rehabilitative hospitals which offer unique and critical care to the populations where they exist. The support demonstrated by Congress to keep both rural hospitals and rehab facilities operating at maximum efficiency while offering the best quality care is imperative to protect vulnerable patients.

Health care cost trend data released last week only further supports the FAH belief that the historic spending slowdown trend occurring throughout health care is foundational and should be left alone by policymakers. The best decision now is to let the system work and reap the benefits of trillions of dollars in additional savings and deficit reduction. At the same time, policymakers must focus on the long-term demographic trends that will ultimately lead to an increase in health care spending.

There is much at stake regarding the fiscal health of the country. Hospitals have done their part to help reform health care and bring costs down. These cumulative cuts, delivery reforms and structural changes are having a significant impact on the spending slowdown, and these savings are expected to last for the next decade. This is why hospitals call upon policymakers to let the system work and stop any further cuts from up-ending this fortuitous, and historic trend we are experiencing now.

As Members return to their districts, FAH applauds your efforts to protect patients and supports an end to any further health care cuts when Congress resumes legislative work this fall.

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Protect Access to High Quality Inpatient Rehabilitation Care

July 18, 2013 | FAH Hospital Policy Blog

Category: Medicare, Rehabilitation Care

“You need to come home, Dad has had a stroke and he’s in the hospital.” It’s the phone call no one wants to receive about an ailing loved one. What can follow a medical event like a stroke is a loved one’s discharge from a general acute hospital and admission to a rehabilitation hospital to help your family member or friend recover. Rehabilitation hospitals, also known as inpatient rehabilitation facilities, or “IRFs,” serve a critical and important role in our healthcare system. The unique role of IRFs and their caregivers is highlighted in a recent Congressional letter to Secretary Sebelius, signed by 83 Members of Congress. Now, the stability of IRF care is in jeopardy. Recent attempts to dramatically cut funding would restrict access for seniors most in need.

In 2011, nearly 4% of all Medicare beneficiaries receiving benefits under traditional Medicare (i.e., non-managed care) experienced a stroke. After their stay in a general acute care hospital many of these patients required intensive rehabilitation and therapy services, ongoing medical care and management by a rehabilitation physician, and constant nursing care. So, they were discharged to a rehabilitation hospital or hospital-based rehabilitation unit to have those needs met.

The “60% Rule”

For a rehabilitation hospital to qualify for classification as an IRF by Medicare, it is required to meet various facility classification criteria. One such criterion is called the “60% Rule,” which requires an IRF to treat at least 60% of its patients, Medicare and non-Medicare, who have medical conditions or diagnoses from among a list of 13 medical categories, such as strokes, neurological impairments (for example, multiple sclerosis or Parkinson’s disease), spinal cord injury, hip fracture, and cases involving major traumas.

The 60% Rule was established in the early 1980s (originally as a 75% Rule) when Congress began paying general acute care hospitals prospectively under the diagnosis related group, or “DRG”-based system. It was recognized that the DRG-based system would not be appropriate for IRFs due to different cost structures associated with IRFs’ medical, therapy, and nursing programs. The difference in cost structures is influenced in part by the fact that IRF patients have longer stays compared to general acute care hospital patients.

Until 2002, IRFs were paid on a “cost-plus” basis; when CMS implemented a prospective payment policy for IRFs (the “IRF PPS”) the 75% Rule was maintained. CMS revised the Rule in 2004 and the impact of those revisions in conjunction with how the Rule’s quota-based nature works caused an erosion of patients’ access to IRF services.

Congress was concerned about this access erosion, and in 2007 established a “permanent” 60% Rule. This policy decision was based on strongly supported bi-cameral legislation (61 Senate co-sponsors, 240 House co-sponsors) and was “paid for” by the elimination of IRFs’ annual “market basket” update during the last half of FY 2008 and all of FY 2009 (Important fact: this market basket cut substantially exceeded the cost of establishing a permanent 60% Rule–in fact, it helped pay for the 2008 “doc fix”).

New Cuts Threaten Patient Access

Yet just a few years later, the Administration wants to revisit the 60% Rule by ratcheting it back up to 75%–which would erode patients’ access to IRF services and force more of them into nursing homes. Additionally, the Administration wants to pay IRFs nursing home-based rates for certain conditions. This would be short-sighted and ill-advised as IRFs and nursing homes are different care settings that provide rehabilitation and therapy through fundamentally different program structures. Both of these policies would significantly and adversely impact patients who depend on high quality rehabilitation care.

The letter, signed by 83 Members of Congress, reiterates these points Secretary Sebelius.

Letter Signed By:

Rep. Robert Aderholt (AL)
Rep. Ron Barber (AZ)
Rep. Lou Barletta (PA)
Rep. Andy Barr (KY)
Rep. Rob Bishop (UT)
Rep. Sanford Bishop (GA)
Rep. Marsha Blackburn (TN)
Rep. Jo Bonner (AL)
Rep. Robert Brady (PA)
Rep. Mo Brooks (AL)
Rep. Vern Buchanan (FL)
Rep. Larry Bucshon, M.D. (IN)
Rep. Shelley Moore Capito (WV)
Rep. Steve Chabot (OH)
Rep. William “Lacy” Clay (MO)
Rep. Mike Coffman (CO)
Rep. Steve Cohen (TN)
Rep. Jim Cooper (TN)
Rep. Rick Crawford (AR)
Rep. Rodney Davis (IL)
Rep. Charlie Dent (PA)
Rep Scott DesJarlais, M.D. (TN)
Rep. Jeff Duncan (SC)
Rep. William Enyart (IL)
Rep. Stephen Fincher (TN)
Rep. Chuck Fleischmann (TN)
Rep. Trent Franks (AZ)
Rep. Bob Gibbs (OH)
Rep. Louie Gohmert (TX)
Rep. Bob Goodlatte (VA)
Rep. Paul Gosar (AZ)
Rep. Kay Granger (TX)
Rep. Morgan Griffith (VA)
Rep. Michelle Lujan Grisham (NM)
Rep. Brett Guthrie (KY)
Rep. Ralph Hall (TX)
Rep. Andy Harris, M.D. (MY)
Rep. Vicky Hartzler (MO)
Rep. Alcee Hastings (FL)
Rep. Joe Heck, D.O. (NV)
Rep. Lynn Jenkins, CPA (KS)
Rep. Bill Johnson (OH)
Rep. David Joyce (OH)
Rep. Joseph Kennedy III (MA)
Rep. Adam Kinzinger (IL)
Rep. Ann Kirkpatrick (AZ)
Rep. Ann Kuster (NH)
Rep. Frank LoBiondo (NJ)
Rep. Stephen Lynch (MA)
Rep. Jim Matheson (UT)
Rep. James McGovern (MA)
Rep. Patrick Murphy (FL)
Rep. Tim Murphy (PA)
Rep. Richard Neal (MA)
Rep. Richard Nugent (FL)
Rep. Pete Olson (TX)
Rep. Steve Pearce (NM)
Rep. Scott Perry (PA)
Rep. Pedro Pierluisi (PR)
Rep. Chellie Pingree (ME)
Rep. Ted Poe (TX)
Rep. Mike Pompeo (KS)
Rep. Bill Posey (FL)
Rep. Nick Rahall (WV)
Rep. Martha Roby (AL)
Rep. Phil Roe, M.D. (TN)
Rep. Mike Rogers (AL)
Rep. Ileana Ros-Lehtinen (FL)
Rep. Keith Rothfus (PA)
Rep Jen Runyan (NJ)
Rep. Bobby Rush (IL)
Rep. Austin Scott (GA)
Rep. Bill Shuster (PA)
Rep. Chris Smith (NJ)
Rep. Lamar Smith (TX)
Rep. Steve Southerland (FL)
Rep. Glenn Thompson (PA)
Rep. Mac Thornberry (TX)
Rep. John Tierney (MA)
Rep. Niki Tsongas (MA)
Rep. Lynn Westmoreland (GA)
Rep. Robert Wittman (VA)
Rep. Kevin Yoder (KS)

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