After years of advocacy by AAPM&R and its physician volunteers, the Medicare Payment Advisory Commission (MedPAC) announced in its June 2024 report to Congress that it is halting its work on developing a recommendation for site-neutral payment policies for care provided in the Inpatient Rehabilitation Facility (IRF) setting. This represents a major victory for both providers and patients in the IRF setting and comes after intense, sustained advocacy from AAPM&R and other stakeholders.
In its report to Congress, MedPAC acknowledges that comparing patients treated in IRFs and SNFs and their outcomes was significantly more challenging than expected. For background, MedPAC is an independent legislative branch agency established by Congress in 1997 to advise on issues affecting the Medicare program, including payment systems.
The Academy worked to ensure that physiatry’s voice was taken into account during MedPAC’s deliberations on this issue and collaborated with other stakeholder organizations to advocate against site-neutral payment policies and the development of a Unified Post Acute Care Prospective Payment System. These efforts included submitting and co-signing comment letters (2013, 2015, 2016, 2019, 2020, 2021, 2022), participating in multiple Technical Expert Panels (TEPs), meeting with Congressional offices and MedPAC staff, testifying before the U.S. Congress, and creating Principles for a Medicare Unified Post-Acute Care Payment System to advocate for prioritizing patient needs and appropriate compensating physiatrists.
While MedPAC’s decision to halt its efforts to develop a recommendation for site-neutral payment policies in the IRF setting is positive news for physiatrists and the patients who rely on PM&R for their healthcare, this report did recommend lowering IRF payments by 5% for FY2025. The Academy does not support this recommendation, and Congress would have to pass legislation for this cut to go into effect. The Academy continues to actively engage with MedPAC, Congress, and CMS on payment issues and will continue to monitor and respond to any further related developments from relevant federal actors.
The report also discusses other steps Centers for Medicare and Medicaid Services (CMS) to consider taking, including improving the definition and identification of patients that do or do not require IRF care, gaining information from the ongoing IRF Review Choice Demonstration (RCD) project, and exploring other approaches to increase auditing of IRF admissions. Furthermore, the full report includes other important recommendations related to updating physician payment rates, boosting participation in alternative payments models, and prior authorization reform in the Medicare Advantage program.
If you have any questions or comments on MedPAC’s June report to Congress, please contact the AAPM&R Health Policy team at healthpolicy@aapmr.org.