ISASS Comments on 2021 Inpatient Rehabilitation Facility Proposed Rule

On June 11, 2020, ISASS and other organizations sent a comment letter to CMS in regards to the 2020 Inpatient Rehabilitation Facility (IRF) Proposed Rule. The rule had been released in April 2020 and proposed, among other items, an expansion of privileges for nonphysician providers such as nurse practitioners and physician assistants in IRF settings.

The letter expressed concern that the proposal would undermine delivery of and access to physician-led team-based care in the IRF setting, which is critical for both ensuring the health and safety of patients receiving specialized rehabilitation care and differentiating the services that IRFs provide. It also highlighted concern for setting a dangerous precedent for removing physician supervision requirements across all health care settings.

The letter advocated for provision of the highest quality, physician-led, rehabilitation care for patients in IRF settings and disputed CMS’ contention that increased privileges for NPPs would lead to savings increases without affecting patient care. By negatively impacting patient care, the proposal, if adopted, would ultimately increase total health care costs by increasing IRF stays and possible readmission and would reduce patient quality and negatively impact Medicare beneficiary rehabilitation.

To read the proposed rule, click here: [https://www.federalregister.gov/public-inspection/current]

Read the comment letter here.