The AHA yesterday urged the Centers for Medicare & Medicaid Services to address problems with the "60% Rule" for inpatient rehabilitation facilities, especially the policy's "arbitrary access restrictions" for patients with diagnoses outside of the 13 qualifying conditions.

Commenting on the agency's proposed rule for the IRF prospective payment system for fiscal year 2018, the AHA also addressed concerns related to the coding guidelines for the 60% Rule presumptive compliance test and the rule's quality reporting provisions.

"Specifically, while we support several of the proposed coding changes, we have concerns with others, as well as the rule's lack of transparency on the rationale supporting some of these changes," wrote AHA Executive Vice President Tom Nickels. "In addition, we urge CMS to reconsider changes made to one measure in the IRF quality reporting program, and delay the implementation of new standardized patient assessment data elements into the IRF Patient Assessment Instrument."


Skilled nursing facilities. In other regulatory news, the AHA yesterday submitted comments on CMS’ proposed rule for the skilled nursing facility prospective payment system for fiscal year 2018.

In the letter, Ashley Thompson, AHA senior vice president of public policy analysis and development, urged CMS to delay reporting requirements for the standardized patient assessment data elements, and to conduct additional testing before implementing changes to one measure in the SNF quality reporting program. She also requested more insight into any empirical modeling used to inform the agency's proposals for implementing the SNF Value-Based Purchasing program.

The AHA plans to submit separate comments on the agency's advance notice of proposed reforms to the SNF prospective payment system for FY 2019. Comments on the advance notice are due Aug. 25.