Physiatry leadership within rehabilitation hospitals is currently being challenged. This issue isn’t just about scope of practice. It’s about patient care and ensuring quality, comprehensive care that leads to high patient satisfaction and low readmission rates.
Backed by the expertise of volunteer committee members and with strong support from Academy members at large, AAPM&R is focused on systematic issues that are leading to non-physiatrist physicians (and even non-physicians) taking leadership positions within rehabilitation hospitals.
One systematic issue that has been identified are the current Centers for Medicare and Medicaid Services (CMS) definitions for “Rehabilitation Physician” and “Director of Rehabilitation” in IRF settings. The definitions are too broad and have implications for our training programs, reimbursement, and physiatry's position of leadership within IRFs. We advocated for new definitions to be considered for the 2020 IRF Prospective Payment System proposed rule.
On July 31, CMS finalized the IRF Prospective Payment System Rule for 2020. In the final rule, CMS has deferred to the inpatient rehabilitation facility to define and assess the definition of “rehabilitation physician.”
While this is a disappointing outcome, our work is far from over. AAPM&R is taking action.
Your Academy will be convening key stakeholders across rehabilitation to establish consensus guidelines to better define the qualifications of a rehabilitation physician and set clear and necessary expectations and standards for rehabilitation. We believe physiatrists are a necessary and integral leader of the rehabilitation team within the IRF setting.
Collaboration, open dialogue, and a united voice among physiatrists will be essential to our success. In the weeks and months ahead, please be on the lookout for requests from AAPM&R to get involved and to support our efforts. AAPM&R will continue to advocate for the long-term interests of physiatrists, IRFs, Medicare beneficiaries in need of intensive, coordinated, interdisciplinary inpatient hospital rehabilitation, and the Medicare program itself.
Despite this outcome, we are immensely proud of the work more than 1,100 of our members put into advocating against this proposal being finalized. In their preamble to the final rule, CMS acknowledged the comments received from AAPM&R and other collaborators. 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.
Here are the latest updates:
- Present:
- A workgroup of experts recently met to set clear and necessary expectations and standards for inpatient rehabilitation care in the future. More details about their efforts will be released later this year.
- In early 2019, US News & World Report reached out to the Academy for our input on the criteria used in their ranking of the top rehabilitation hospitals in the United States. Our Evidence, Quality, and Performance Committee (EQPC) reviewed their criteria and conducted a survey for Academy members. Our final recommendation states that the qualifications of Medical Directors of Rehabilitation and Rehabilitation Physicians should be included in the criteria. This is one of many ways your Academy continues to advocate for physiatrists role and value within the inpatient rehabilitation setting.
- Fall 2019: Your Academy will be convening key stakeholders across rehabilitation to establish consensus guidelines to better define the qualifications of a rehabilitation physician and set clear and necessary expectations and standards for rehabilitation. Stay tuned to your Academy communications for ways to get involved.
- July 31, 2019: CMS finalized the IRF Prospective Payment System Rule for 2020. In the final rule, CMS has deferred to the inpatient rehabilitation facility to define and assess the definition of “rehabilitation physician.”
- April 17 - June 17, 2019: AAPM&R took the following actions before the comment period deadline. Find additional details in this blog post from AAPM&R President, Peter Esselman, MD, MPT, FAAPMR (member login required):
- Convened an ad hoc Rehabilitation Physician Workgroup with the following leaders – Drs. Peter Esselman, Darryl Kaelin, Steven Flanagan, Michelle Gittler, Nneka Ifejika, and Scott Laker – to address this issue through collaboration with various rehabilitation stakeholders.
- Dr. Esselman and Dr. Kaelin met with the White House’s Office of Management and Budget on June 12 and with CMS officials on June 13 to discuss our concerns and recommendations related to the proposal.
- Submitted strongly worded comments on June 17 to CMS on the Proposed Rule 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. Comments also focused on additional recommendations for removing burdensome requirements from IRF regulations and provided input related to quality measures and standardized data reporting.
- Secured support from 40 prestigious organizations representing patients, physicians, and large inpatient rehabilitation hospitals on a stakeholder letter submitted to CMS on June 17.
- Launched an advocacy campaign that resulted in over 1100 members and IRFs participating by submitting individual letters to CMS.
- Held individual meetings and conversations with leadership from American Medical Rehabilitation Providers Association (AMRPA), American Academy of Neurology (AAN), American Hospital Association (AHA), for-profit IRF companies, American Congress of Rehabilitation Medicine (ACRM), and Uniform Data System for Medical Rehabilitation (UDSMR) to discuss our respective positions and encourage ongoing collaboration with these stakeholders.
- April 17, 2019: CMS released the Proposed CY 2020 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Rule, which states “we propose 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.” The proposal does not address the current definition of a “Director of Rehabilitation” in an IRF.
- March 5, 2019: A delegation from AAPM&R met with members of CMS to discuss our concerns
- February 21, 2019: AAPM&R had an initial conference call with CMS to see what questions they might have and to prepare for the in-person meeting.
- February 11, 2019: AAPM&R sent the updated definitions and position statement to CMS.
- December 2018: The AAPM&R Board of Governors formally approved the position statement and new definitions in order to advocate to CMS for change.
Stay tuned to this webpage and The Physiatrist for the latest updates on this effort.