fah hospital policy blog

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

FAH Comments on FY2018 Proposed IRF PPS Rule

June 27, 2017 | FAH Policy Blog Team

Category: General, Health Care Delivery

The Federation sent a letter to CMS on Monday commenting on several areas of the agency’s FY2018 proposed Inpatient Rehabilitation Facility (IRF) Prospective Payment System.

Among the things included in the letter is a recommendation that the IRF 60 Percent Rule should be eliminated. FAH notes that the rule is not patient-centered and no longer needed in light of new emerging paradigms of health care.

In addition, FAH commented on proposed code modifications for presumptive testing of compliance with the 60 Percent Rule.

FAH also recommended in the letter that CMS test IRF measures before deploying them in quality programs, accounting for social risk factors, such as sociodemographic status adjustment. The letter also asks that CMS develop a robust and fully transparent methodology for proposed changes and updating the Proposed Collection of Standardized Patient Assessment Data under the IRF QRP.

Finally, in response to CMS’s request for information on program flexibilities and efficiencies, FAH recommended that the agency adopt alternative payment models to allow IRFs to carry more risk, while offering relief from certain regulations, such as the three hour therapy rule.

You can read the entire letter here.