Commenting today on the Centers for Medicare & Medicaid Services’ proposed rule for the inpatient rehabilitation facility prospective payment system for fiscal year 2020, AHA said it generally supports the reforms to update the payment system, but expressed concern with the substantial redistribution of cases under the payment model proposed for FY 2020. The comment letter raises concerns regarding the FY 2020 case-mix system reforms finalized in last year’s rulemaking, as well as proposed changes to quality outcomes reporting and patient assessments. “[W]e remain concerned that these new policies are, in part, based on unreliable data and that the proposed rule lacks adequate detail and transparency,” AHA wrote. “We also are concerned that the proposed rule lacks the patient-level and cost data needed to replicate the model for the purpose of evaluating its impact to consider whether alternatives would be warranted. These issues deserve further discussion and transparency in the final rule to allow the field to best prepare for the changes and serve their patients.”

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