AAPM&R has many ongoing initiatives aimed at enhancing the recognition of PM&R medical expertise in inpatient rehabilitation.

AAPM&R is taking action.

AAPM&R has partnered with the American Medical Rehabilitation Providers Association (AMRPA) and the Federation of American Hospitals (FAH) on an innovative project with the HHS Office of Inspector General to address wide variations in error rates found by CMS contractors and OIG on Medicare IRF claims over the past 15 years.  The three organizations are providing data and feedback to OIG as the agency conducts a nationwide audit of IRF claims.  A previous nationwide audit by OIG published in 2018 found an 84% error rate.  At the time, AAPM&R strongly challenged that finding and continued a dialogue with OIG which has led to this initiative.

After months of preparation and review of actual patient cases, the IRF stakeholders recently met with the OIG, its audit contractor, Performant, and CMS officials in June 2025 to discuss medical necessity and documentation requirements in connection with this new audit.  A panel of IRF stakeholders, including rehabilitation physicians and clinicians, association leaders, and legal counsel participated in a wide-ranging dialogue with OIG and its audit contractor, Performant, in an effort to identify key issues that lead to denials of IRF claims.  Government auditors and IRF stakeholders exchanged views and shared different perspectives on a wide variety of IRF medical necessity and documentation requirements with the goal of gaining consensus on areas in need of additional attention to reduce error rates. 

OIG is expected to draft its report on this nationwide IRF audit over the next several months and AAPM&R and the other IRF stakeholders will be able to respond to the draft report before it is published.  The written response will be published as an addendum in the final OIG report, which is expected within the next year.

Critical PM&R Dialogues: Assembly of Delegates Recap

Board of Governors, Future Leaders and Member Community Delegates Discuss Critical Topics

On November 15, 2023 the AAPM&R Board of Governors held their third in-person Critical PM&R Dialogues: Assembly of Delegates meeting. The purpose of this meeting is to gain member input on critical issues impacting the specialty and to provide input to the Board of Governors for the Academy to support members.  

This year’s identified topics were:

1. Discussing current challenges in inpatient rehabilitation.
2. Discussing unique needs for positioning and advocating for PM&R in a cohesive way and coalescing around the primary specialty of PM&R First.
   

Delegates from 24 Member Communities engaged with each other, members of the Board of Governors, Future Leaders and the Inclusion and Engagement Committee. The meeting was hosted by AAPM&R Board member and Inclusion and Engagement Committee Chair, Carla Watson, MD, FAAPMR.  The first topic was facilitated by AAPM&R Past Presidents Peter C. Esselman, MD, FAAPMR and Darryl L. Kaelin, MD, FAAPMR; Dr. Watson facilitated discussion of the second topic.

Attendees participated in discussions regarding challenges in inpatient rehabilitation such as threats within the inpatient rehabilitation space and the importance of preserving the PM&R position and expertise in inpatient rehabilitation. Many agreed that we need to educate stakeholders on the role of a Physiatrist based on an agreed upon definition. They also discussed the need for updates to residency training programs regarding inpatient rehabilitation, which can lead to preventing early burnout. These challenges do not have immediate answers which is why it was important to have more than 40 diverse physiatrists in the room engaging in healthy dialogue to look towards the future of the specialty.

“The conversations around the current challenges in inpatient rehabilitation were very informative and highlighted our challenges. The delegates identified opportunities we can lean in to as we continue our efforts to preserve the important role of PM&R physicians in inpatient rehabilitation settings.” -Dr. Esselman

Major Advocacy Win! CMS does NOT finalize 2020 NPP proposal.

By bringing together the unified voice of 2,377 physiatrists, 122 patient advocacy groups, state and medical specialties, and large IRF hospitals, as well as 97 of your patients, and gaining support from key Congressional offices in the spring and summer of 2020, we successfully defeated a dangerous proposal that would have had a detrimental impact on patient care, the specialty, and the future of inpatient rehabilitation. Click here to view the full story!

Past Efforts

In 2019, the Centers for Medicare and Medicaid Services (CMS) released the Proposed CY 2020 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Rule, including a proposal 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.” In response to this proposal, AAPM&R convened an ad hoc Rehabilitation Physician Workgroup and submitted a strongly worded letter to CMS 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. In additional to several additional advocacy actions, AAPM&R secured support from 40 prestigious organizations representing patients, physicians, and large inpatient rehabilitation hospitals on a stakeholder letter to CMS.

In July 2020, CMS finalized the IRF PPS Rule for 2020. In the final rule, CMS deferred to the IRF to define and assess the definition of “rehabilitation physician.” Despite this outcome, we are immensely proud of the work more than 1,100 of our members put into advocating against this proposal. 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.

Click here to read the full timeline of our efforts.