AAPM&R Submits Comments to CMS Opposing Review Choice Demonstration for IRF Services

Members & Publications

October 12, 2021

Updated as of October 12, 2021

CMS proposed to implement a “Review Choice Demonstration” for IRFs, which would subject selected IRFs to 100% pre-claim or post-claim review of their Medicare claims. We believe that this RCD would add significant burden to physiatrists working in IRFs and fundamentally alter the patient population by allowing MACs to overrule admitting physician decisions and curtail access to IRFs for patients under Medicare coverage if the MAC determines the IRF care is not appropriate for the patient. Thank you to everyone who used our template to submit your own, individualized letter to CMS opposing this proposed IRF RCD. Read our full comments to CMS that we submitted last Friday, October 8.


Originally published on February 16, 2021

On February 16, AAPM&R delivered comments to The Centers for Medicare and Medicaid Services (CMS) in response to the proposed information collection on a Review Choice Demonstration (RCD) for Inpatient Rehabilitation Facility (IRF) Services (CMS-10765).

CMS proposes to implement a “Review Choice Demonstration” for IRFs, which would subject selected IRFs to 100% pre-claim or post-claim review of their Medicare claims. While this demonstration would begin with all IRFs in Alabama, CMS proposes to expand the RCD to all providers in four Medicare Administrative Contract (MAC) jurisdictions, covering 17 states, three U.S. territories, and the District of Columbia.

We have significant concerns with this proposal, which would dramatically increase physician burden in a field already subject to onerous documentation requirements. It would also serve as an unprecedented intrusion by CMS contractors in the exercise of independent physician judgment. As such, we are urging CMS to withdraw this proposal and work to develop a less onerous alternative that meets CMS legitimate need to only pay for medically-necessary care, while preserving patient access to vital inpatient rehabilitation hospital services.

We also asserted in our comments that if CMS is concerned about IRFs admitting patients who do not medically need IRF care, CMS should consider requiring physiatrists to be in the position of rehabilitation physician to ensure that appropriate patients are being admitted to and treated in IRFs. AAPM&R consistently advocates for the role of the physiatrist and the definition of a rehabilitation physician in the IRF setting.

However, if CMS decides to proceed with this demonstration, we urge the agency to significantly restructure the demonstration program in a manner that reduces physician burden and maximizes patient access.

Read our full comment letter here.

On February 19, AAPM&R and the American Medical Rehabilitation Providers Association (AMRPA) released a joint statement urging CMS to withdraw its proposal to implement the demonstration.

Read the full joint statement here.

During this initial comment period, many key rehabilitation stakeholders, including AAPM&R allies and patient-centered coalitions, echoed our concerns about the potential consequences of moving forward with this demonstration.

Read the comments made by our allies here.

We will keep our members informed about the final outcome via the Academy's communication channels.

To learn more about our advocacy efforts, we invite you to attend AAPM&R Advocacy: Advancing PM&R on Capitol Hill and Beyond, an informational webinar hosted by our advocacy committees on Thursday, March 4, at 7 pm (CT).

Our advocacy committees look forward to receiving input from AAPM&R members during this session on our ongoing and upcoming advocacy priorities, including physician reimbursement, telehealth, scope of practice, COVID-19 and post-acute COVID syndrome, social determinants of health and Medicaid expansion.

Learn more and register for our March 4 webinar today.

Legislation Introduced to Alleviate Impact of Conversion Factor Cut for 2021

Nov 09, 2020

Last month, two bills were introduced in the House proposing solutions to the estimated 10.6% Physician Fee Schedule conversion factor cut expected to go into effect January 1, 2021.  The bills offer some relief to the cut, but do not reflect a comprehensive or long-term solution.  AAPM&R has therefore chosen to remain neutral regarding these bills. 

Your Academy continues to advocate for a permanent solution to the conversion factor cut while maintaining the important payment increases to office and outpatient evaluation and management services.