The AHA today urged the Centers for Medicare & Medicaid Services not to implement a new market basket specific to inpatient rehabilitation facilities until the agency can ensure it accurately reflects costs for freestanding and hospital-based IRFs. “Dobson Davanzo & Associates replicated CMS’s calculation of the proposed IRF-specific market basket and has identified concerns that are shared by the AHA,” wrote AHA Executive Vice President Rick Pollack, commenting on the IRF prospective payment system proposed rule for fiscal year 2016. AHA also urged CMS to “develop and make publicly available a comprehensive plan describing how it will implement the provisions of the IMPACT Act in all of its post-acute care quality programs,” and to adhere to four principles in implementing the Act. In addition, AHA said it objects to the proposed FY 2018 functional status measures, which are not endorsed by the National Quality Forum, duplicate existing quality reporting requirements and fail to capture important functional changes in the patient population; and recommends using Functional Independence Measure data to calculate functional status measures. AHA also urged CMS to incorporate risk adjustment and adequately test on IRF patients the proposed fall with major injury measure, and to adjust the proposed readmission measure for sociodemographic factors.