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AAPM&R Comments on CMS 2017 IRF Proposed Rule

Jun 30, 2016

On April 21, the Centers for Medicare & Medicaid Services (CMS) released the inpatient rehabilitation facility (IRF) prospective payment system (PPS) proposed rule for fiscal year (FY) 2017. In a comment letter submitted on June 20, the Academy urged CMS to modify the compliance-2 presumptive methodology and the accompanying code lists by incorporating all instances in which IRF-Patient Assessment Instrument (PAI) data can be used to identify the defined qualifying conditions. Specifically, we recommended that CMS remove presumptive compliance etiologic diagnosis exclusions for traumatic brain injury patients in impairment group codes (IGCs) 02.21 and 02.22. Additionally, the Academy urged CMS to delay its proposal to adopt any quality measures that have not been fully assessed to determine if the measures will have a positive impact on health care quality, are scientifically acceptable, are applicable and relevant for quality improvement and decision making, and feasible to collect without undue burden. The Academy also signed on to the CPR IRF comment letter that aligned closely with our comments.