AAPM&R Submits Comments on SNF and IRF Proposed Rules

June 22, 2017

On June 22, 2017, your Academy submitted comments to the Centers for Medicare and Medicaid Services (CMS) on 2 proposed rules:

• CMS 1679-P Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities for FY 2018, SNF Value-Based Purchasing Program, SNF Quality Reporting Program, Survey Team Composition and Proposal to Correct the Performance Period for the NHSN HCP Influenza Vaccination Immunization Reporting Measure in the ESRD QIP for PY 2020
  
  • The Academy requested that CMS work to better educated Medicare Administrative Contractors on appropriate coverage for PM&R services in the SNF setting.
  • The Academy also provided feedback on the importance of standardization of patient assessment data in the post-acute setting. 
• CMS 1671- P Medicare Program; Inpatient rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2018
  
  • The Academy argued for the inclusion of codes for traumatic brain injury with loss of consciousness of unspecified duration for compliance under the 60% rule.
  • The Academy also provided extensive feedback on issues related to administrative burden.  

For both rules, the Academy encouraged CMS to include sociodemographic factors in their risk adjustment for quality programs and commented on quality measures related to self-reporting of pain and patients who newly receive an antipsychotic medication.

Learn more about the Academy's reimbursement advocacy efforts.