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Site Neutral Payment Proposal Has Flawed Understanding of Rehabilitation

Written by: Darlene D'Altorio-Jones (1959-2015) on Monday, September 8, 2014 Posted in: Other

Access to IRF/U intensity of Care Can be Compromised

Congress is discussing payment neutral options right now and it’s clearly evident that the persons involved have a very narrow perspective on just one word – ‘REHABILITATION’ and that it can generically be substituted as the same experience no matter where care is provided.

Rehabilitation provided at a skilled and IRF/U are not comparable. The resources and clinical care and oversight provided at an IRF level of care is far greater than a SNF. Regulations demand differences in the cost and resources of various venues of rehabilitation.

NOW is the time to engage yourself in this conversation with your political leaders so that distinct levels of service are understood along with those outcomes when a patient truly requires the unique skills and management at an IRF/U level of service.  If you don’t speak up now, you may be reimbursed in the future for providing a mandated level of service from a resource perspective that compensates far less than costs incurred. The fact that recent studies have demonstrated outcomes that differ dependent on the level of services received favor IRF for return to acute care in 30 days, overall independence and lengthened life-span.

American Medical Rehabilitation Providers Association, AMRPA, has set out to advocate and educate that voices in the rehabilitation profession are needed right now in this narrow window of September when law makers can make a vote.

AMRPA stated in a recent release, “Inpatient rehabilitation hospitals and units remain at risk as policymakers continue to consider Medicare cuts, including post-acute care cuts, such as site neutral payments.  The risk is heightened as Congress works to identify offsets for the IMPACT Act and a Medicare physician payment package.  The Medicare Payment  Advisory Commission (MedPAC) suggested in its June 2014 Report to Congress that legislators could implement “site neutral” payments to IRH/Us and SNFs beginning  with major joint replacement cases and hip and femur procedures.” AMPRA’s goal “is to educate Members of Congress and staff about why the site neutral payment policy should not be implemented without a better understanding of the impact on patient care and outcomes.” And they ask that YOUR Members of Congress contact Rep. Kevin Brady (R-TX), Chairman of the Ways and Means Health Subcommittee, and Rep. John Boehner (R-OH), Speaker of the House, to oppose any post-acute care site neutral payment policy.”

Educating policy makers on the distinct and separate regulatory requirements that IRF’s must follow and are not applicable to SNF’s. Services and resources are held to a higher standards in an IRF/U. Here are some examples:

  • Admission criteria that define medical necessity at the intensity only available within IRF’s.
  • Physician oversight no less than 3x/week for medical and FUNCTIONAL care planning.
  • Availability 24/7 of RN nursing care consistent with the knowledge of specialized rehabilitation. SNF national RN hPPD are less than 1 hour per patient day posted on the CMS SNF web compare.
  • Interdisciplinary care planning with no less than 15 hours of therapy per week, predominantly provided at 3 hours /day no less than 5 days per patient calendar week.

Comparison tools have been lacking to do a side by side exact compare for outcomes even though recent studies have shown health outcomes to be better for similar patient types when provided in IRF/U over SNF, these include improved independence and mortality ‘post acute care’ discharge.  Return to acute care within 30 days of discharge is significantly less than that from an IRF.   These all indicate that complexity and carry-over for patient education and care givers may not be adequate when provided at the less intense SNF resource levels.

Be certain you contact your legislative representatives as inaction at this time could further cloud access to care at an intensity required by some patients screened and deemed appropriate for an IRF/U level of service. Confusing site neutrality for level of rehabilitation and resources would only serve to reduce appropriate access to those patients that truly require skill sets above and beyond a SNF level of care.

Don’t wait!