AHA Comments on CMS Inpatient Rehabilitation Facility FY 2026 Proposed Payment Rule

June 10, 2025

The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2026 and Updates to the IRF Quality Reporting Program; 90 Fed. Reg. 18,534 (April 30, 2025).

Dear Administrator Oz:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 900 inpatient rehabilitation facilities (IRF), our clinician partners — more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2026 IRF prospective payment system (PPS) proposed rule.

IRFs play a critical role for Medicare beneficiaries in the continuum of care. These hospitals and units of acute-care hospitals care for patients with complex conditions as they undergo an intensive course of rehabilitation while being monitored and treated by a rehabilitation physician, which provides the optimal opportunity for maximum functional recovery following a serious injury or illness. The treatment provided by IRFs pays dividends down the road, allowing patients to return to their previous lives to the maximum extent possible.

The AHA has concerns that Medicare payment updates continue to lag inflation and may not be adequate for the continued success of the IRF field. As discussed more thoroughly below, we urge CMS to examine its market basket and productivity adjustments to ensure appropriate annual updates. The AHA appreciates, however, CMS’ efforts to alleviate the reporting burden on providers. Specifically, the AHA supports CMS’ proposal to remove four standardized patient assessment data elements (SPADEs) from the IRF QRP and greatly appreciates CMS’ recognition of the need to balance administrative burden and value in quality measurement programs. By streamlining reporting requirements, CMS can free providers to focus on the quality and safety issues that matter the most to their patients. In addition, the AHA appreciates CMS’ efforts around deregulation and is responding to CMS’ Request for Information (RFI) on approaches and opportunities to streamline regulations and reduce administrative burdens on providers.

Our detailed comments follow.