In comments sent today to CMS and OMB on its information collection for developing an Inpatient Rehabilitation Facility (IRF) Review Choice Demonstration, FAH urged CMS to withdraw the proposed program that would require either 100 percent pre-claim review or 100 percent post-payment review for all IRF patients to prevent and identify potential fraud in select states and Medicare Administrative Contractor (MAC) regions.
FAH commented that the Review Choice Demonstration is flawed, would lead to significant patient access gaps, relies on failed approaches for auditing medical necessity of inpatient rehabilitation, and would create an excessive level of regulatory burden that will divert resources from patient care to paperwork. The letter also urged CMS to delay further development and implementation until after the COVID-19 public health emergency (PHE).
This is the second opportunity CMS has provided to offer comments on the IRF RCD. This proposal offered only slight revisions and left most of the program as proposed. The FAH has been working with partners at the American Medical Rehabilitation Providers Association (AMPRA) and the American Academy of Physical Medicine and Rehabilitation (AAPM&R) to evaluate the IRF medical review process and meet with CMS staff on the issue.
Read the letter here.