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Urgent Actions Taken This Week Regarding IRF Coverage Criteria, Prior Authorization for Spasticity and Medicare Enrollment Provisions

Sep 03, 2026

 

This past Monday, August 31, AAPM&R, led by our physician volunteer leaders, advocated on several critical areas on behalf of PM&R physicians: 

Urgent concerns regarding the initial Interdisciplinary Team (IDT) conference and other new requirements in the 2027 Inpatient PPS Final Rule 

  • AAPM&R comments to CMS call for two new Inpatient Rehabilitation Facility (IRF) coverage criteria policies to be rescinded and request an urgent meeting to discuss our recommendations ahead of the October 1 implementation date. AAPM&R is advocating against new requirements that will create significant challenges for PM&R physicians and IRFs to: 

  • Operationalize a new requirement that the initial IDT conference must occur within four days of admission, an update from the current requirement of seven days. 

  • Implement a new requirement that all therapies be initiated within 36 hours from midnight on the day of admission. 

  • We have recently learned that CMS will host a national provider education webinar for IRF providers on Tuesday, September 29, 2026, from 12 – 1 pm CT. AAPM&R physician volunteer leaders will attend to advocate for PM&R. We encourage all members to attend to ask questions and voice their concerns. Register here.  
     

Significant concerns regarding expansion of prior authorization processes related to botulinum toxins and more in the Medicare Outpatient Prospective Payment System 

  • AAPM&R comments to CMS  on this rule focus heavily on our concerns regarding expansion of prior authorization processes related to botulinum toxins and also include our support for the development of new coding pathways for digital healthcare. 

  • We also asked members to take action through Voter Voice. Thank you to the 83 #PMRAdvocates who took action on this campaign to help protect treatment for conditions such as spasticity and dystonia. 

Concerns regarding Medicare enrollment and more in the Home Health Prospective Payment System Proposed Rule  

  • AAPM&R comments to CMS  include concerns that many of the enrollment policies in the proposed rule lack transparency, predictability, proportionality, or procedural safeguards. 

  • AAPM&R cosigned comments with the Coalition to Preserve Rehabilitation to CMS  including highlighting the potential consequences of these proposals that will threaten the availability and continuity of rehabilitation services for Medicare beneficiaries.