Latest Efforts and Resources

Advocacy

Scope of practice expansion is a long-standing, continuous, and complex concern in the health care field. AAPM&R is aware of the various concerns specifically plaguing physiatrists, from non-physicians to non-physiatrists, intent on expanding their scope of practice beyond their level of education, training, and experience. 

AAPM&R is taking action.

Your Academy remains vigilant about ongoing efforts by non-physician and non-PM&R providers to expand their scope of practice beyond their level of training, which may threaten the health and safety of patients and impact the livelihood of physiatrists.

AAPM&R's Scope of Practice Workgroup

Recognizing the growing concern of non-physician (and non-PM&R) scope of practice expansion, your Academy is addressing this issue through multiple committees, including a new Scope of Practice Workgroup. This workgroup is comprised of representatives from the Quality, Practice, Policy, and Research (QPPR) Committee, the Health Policy and Legislation (HP&L) Committee, and the Reimbursement and Policy Review Committee (RPRC), and AAPM&R’s representative to the AMA Scope of Practice Partnership (SOPP).

Scope of Practice Partnership with the American Medical Association (AMA)

Your Academy, as a member of the AMA Scope of Practice Partnership (SOPP), actively engages in the collaborative effort of the AMA, American Osteopathic Association (AOA), national medical societies, state medical associations and state osteopathic medical associations to oppose scope of practice expansions by non-physician providers that threaten the health and safety of patients. The SOPP achieves this goal through legislative activities, regulatory activities, judicial advocacy, and programs of information, research and education. Active participation in this collaborative ensures physiatry is represented and contributes to SOPP’s goal to protect the health and safety of patients whose well-being may be threatened by health care practitioners who lack the education, training or experience to perform procedures for which they seek licensure or recognition.

Protecting Physiatry’s Leadership Within Rehabilitation Hospitals

In 2019, the Centers for Medicare and Medicaid Services (CMS) released the Proposed CY 2020 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Rule, including a proposal to amend the definition of a rehabilitation physician to clarify that the determination as to whether a physician qualifies as a rehabilitation physician (that is, a licensed physician with specialized training and experience in inpatient rehabilitation) is made by the IRF.” In response to this proposal, AAPM&R convened an ad hoc Rehabilitation Physician Workgroup and submitted a strongly worded letter to CMS urging CMS not to finalize its proposal to weaken the definition of rehabilitation physician and requesting that CMS delay any changes to current regulations until stakeholders can develop a consensus approach for protecting the quality and integrity of IRF care. In additional to several additional advocacy actions, AAPM&R secured support from 40 prestigious organizations representing patients, physicians, and large inpatient rehabilitation hospitals on a stakeholder letter to CMS.

In July 2020, CMS finalized the IRF PPS Rule for 2020. In the final rule, CMS deferred to the IRF to define and assess the definition of “rehabilitation physician.” Despite this outcome, we are immensely proud of the work more than 1,100 of our members put into advocating against this proposal. Our members demonstrated that physiatrists are advocates for their patients, in and out of the treatment setting. We know it will take time and perseverance to be successful, but we are stepping up and planning a long-term, strategic initiative. We are making physiatrists’ voices heard. We are advocating for physiatry’s value in medicine.

Click here to read the full timeline of our past efforts.

Click here to read about AAPM&R’s leadership in scoring an enormous advocacy win for the FY 2021 IRF PPS Proposed Rule.

Resources

From ongoing collaborations with the American Medical Association (AMA) to a full toolkit of position statements, we plan to continue developing tangible resources to assist physiatrists in addressing scope of practice issues.

Your Academy's Latest Efforts to Defend Physiatrists' Scope of Practice

BREAKING: AAPM&R Leads Effort to Unite Team Physiatry to Score an Enormous Advocacy Win

Aug 04, 2020

AAPM&R is thrilled to announce that our leadership efforts have resulted in a BIG WIN for physiatry! By bringing together the unified voice of 2,377 physiatrists, 123 patient advocacy groups, state and medical specialties, and large IRF hospitals, as well as 97 of your patients, and gaining support from key Congressional offices, we have successfully defeated a dangerous CMS proposal that would have had a detrimental impact on patient care, the specialty, and the future of inpatient rehabilitation.

CMS heard us! In the rule released today, August 4, 2020, CMS did NOT finalize their proposal, as written, to amend the IRF coverage requirements to allow non-physician practitioners (NPPs) to perform certain duties that are currently required to be performed by a rehabilitation physician. CMS is finalizing that an NPP may perform one of the three required face-to-face visits in lieu of the rehabilitation physician in the second and later weeks of a patient’s IRF stay, when consistent with the NPP’s scope of practice under applicable state law. Rehabilitation physicians will continue to have the flexibility to see the patient on three or more occasions per week, as is currently permitted. CMS is continuing the requirements that a rehabilitation physician review and concur with the preadmission screening for the IRF admission, establish and implement the overall plan of care, and lead the weekly interdisciplinary team conferences, which include rehabilitation nurses, social workers or case managers, and treating therapists carrying out the patient’s care plan.

"Those of us leading this advocacy effort are so pleased that CMS heard our voice and heeded our concerns. There is still work ahead but we are so thankful to everyone who helped us in this effort. Our patients and our specialty are better for it."

Darryl Kaelin, MD, FAAPMR
AAPM&R Past President
Co-Chair, Future of Inpatient Rehabilitation Workgroup

By leading this effort, and with your help and support, AAPM&R successfully united all physiatrists and other stakeholders to keep inpatient rehabilitative care duties in the hands of the rehabilitation physician. This is a monumental win and would not have been possible without the engagement of our members and other key supporters. Thank you!

We are also thrilled to announce CMS’ decision to remove the post-admission physician evaluation (PAPE) documentation requirement, effective October 1, 2020. Your Academy has long advocated to reduce burden for physiatrists by streamlining administrative documentation. CMS’ decision to remove the PAPE is a direct result of our persistent advocacy. As proposed, CMS has also codified into regulation certain elements of the pre-admission screening (PAS); however, they have removed three elements from the Medicare Benefit Policy Manual including expected frequency and duration of treatment in the IRF, any anticipated post-discharge treatments, and other information relevant to the patient’s care needs.

AAPM&R’s advocacy work provides what individual PM&R physicians cannot easily do alone — influence the trajectory of PM&R in health care and help advance the future of the specialty. We track and influence legislation and policy issues; advocating on behalf of our members and positioning PM&R doctors as leaders across the health care continuum.

Our advocacy does not stop here. AAPM&R actively asserts our position that physiatry-led, patient-centered, team-based care is the best approach to providing optimized medical rehabilitation care for patients. Physiatrists are necessary and integral leaders of the rehabilitation care team within the IRF setting and we will continue to advocate for the long-term interests of physiatrists in IRFs and patients in need of intensive, coordinated, interdisciplinary inpatient hospital rehabilitation.

Collaboration, open dialogue, and a united voice among physiatrists will be essential to our success. In the weeks and months ahead, please watch for updates from our Future of Inpatient Rehabilitation Workgroup and requests from AAPM&R for you to stay involved and support future efforts.

Team Physiatry’s success is driven by you. Thank you for being a #PMRAdvocate and getting involved! We couldn’t do it without you.

AAPM&R will continue to review the final rule in its entirety and to share further updates with you. To read the finalized IRF Prospective Payment System Rule for 2021, click here.