Inpatient Rehabilitation Facility Prospective Payment System Proposed Rule for Fiscal Year 2021

On April 16, 2020, the Centers for Medicare and Medicaid Services (CMS) released an ill-timed proposed rule for the Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) for Fiscal Year 2021. The proposed rule, among other provisions, includes a shocking proposal 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.


Your Academy has strongly opposed similar CMS proposals to expand the role of NPPs in IRFs in the past. We are now leading an effort to unite all physiatrists, other medical specialties, patient coalition organizations, and additional key stakeholders to oppose this dangerous proposal.  

Join us on this important initiative. CMS is requesting public comments on the proposal by June 15, 2020.

Frequently Asked Questions about the FY2021 IRF PPS Proposed Rule

TIMELINE: Team Physiatry Works to Defeat FY2021 IRF PPS Proposed Rule


Academy in Action: AAPM&R's Game Plan

AAPM&RWhat can you do to defeat this proposal? AAPM&R’s ability to oppose this proposal depends on YOU. Here’s how you can help:

  • Attend the virtual Advocacy Open Forum: IRF Proposed Rule on June 2 at 6 pm CT, to help us mobilize our response to this proposal. Learn more here. Panelists include:
    • Thiru M. Annaswamy, MD, MA, AAPM&R Quality, Practice, Policy, and Research (QPPR) Committee Chair
    • Peter C. Esselman, MD, MPT, AAPM&R Future of Inpatient Rehabilitation Workgroup Co-Chair
    • Darryl L. Kaelin, MD, AAPM&R Future of Inpatient Rehabilitation Workgroup Co-Chair
    • Cindy Moon, MPP, MPH, Vice President, Health Care Payment and Delivery Reform, Hart Health Strategies in Washington, DC
  • Submit a customized letter to CMS by June 15, 2020 via AAPM&R's Advocacy Action Center. As of May 28, more than 350 physicians have written to CMS using our template.
  • Ask your patients to write a letter to CMS by June 15, 2020. As of May 28, more than 15 patients have used our customizable patient letter to tell CMS they oppose the proposed amendment and detail the impact your knowledge, experience, and quality of care has had on them.
  • A customizable letter to CMS for PM&R Department Chairs and PM&R Division Chiefs is available upon request. Send an email to for more information.
  • Ask your hospital to oppose the NPP proposal in the IRF Proposed Rule.
  • Contact your Congressional Representative asking them to urge CMS not to finalize this proposal. We'll be adding talking points to the Advocacy Action Center soon.
  • On May 12, your Board of Governors held a virtual town hall to provide members with an update on the Academy's response to this proposal and provided an opportunity to share feedback and input.

    See how the Academy has been defending physiatric-led care in rehab hospitals.

    AAPM&R is Leading the Effort for a Unified Response

    Your Academy is leading efforts to join other medical societies and key stakeholders to raise a unified voice against this proposal. As our collaborations continue into the coming weeks, we will be engaging the entire specialty in our response efforts. Please continue to check AAPM&R’s Game Plan above for additional actions you can take to get involved.

    Team Physiatry’s advocacy is driven by you. Be a #PMRAdvocate and get involved now!