Skilled nursing facilities (SNFs), inpatient rehabilitation facilities (IRFs), and prospective payment systems for acute and long-term care are the subjects of newly available APTA comments on proposed rules from the Centers for Medicare and Medicaid Services (CMS).
In the SNF letter (.pdf), APTA commends the agency for its work to create an alternative therapy payment methodology and encourages the inclusion of a standardized assessment tool as well as a universal therapy payment model across all postacute care settings. APTA also thanks CMS for its proposal to ease SNF assessment requirements and urges the agency to provide educational resources to providers on how the change will apply to all SNF assessments.
APTA's letter on IRFs (.pdf) urges CMS not to adopt proposals that would change the 60% rule presumptive compliance list, specifically the deletion of amputation and prosthetic status codes. Most notably, the association strongly recommends that CMS halt finalization of policies to implement a definition and IRF Patient Assessment Instrument (IRF-PAI) reporting requirement for group therapy. As an alternative, APTA recommends that CMS collect data regarding the delivery of therapy in the IRF setting.
A separate APTA letter on inpatient prospective payment systems and long-term care hospitals (.pdf) includes several recommendations regarding the 2-midnight admission criteria, short stays, and observation status. Specifically, APTA recommends that any therapy services provided as inpatient or observation stay be exempted from outpatient therapy requirements such as functional limitation reporting and the therapy cap. In addition, APTA supports the changes made to the hospital readmission reduction program and makes suggestions to improve the long term care hospital quality reporting program.
CMS will consider all comments submitted and issue final rules for these settings around August 1, 2014.
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