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Tags Posts tagged with "AMRPA"

AMRPA

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On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.

If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:

Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.

RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:

Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the ‎reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.

Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following ‎information:‎

  • A copy of the CMS non-compliance letter;
  • A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of ‎calendar year 2024; and
  • If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the ‎monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract ‎Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among ‎Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.

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NOTE TO INSPECTOR: The word "iridium" on the pen's nib is not a brand: it's the name of the metal of which the nib is made. Thanks. Inky old fountain pen on a $100 bill.

The Medicare Payment Advisory Commission (MedPAC) held their regular public meeting on January 16 – 17, 2025. During one of their presentations, “Assessing Payment Adequacy and Updating Payments: Skilled Nursing Facility Services; Home Health Agency Services; Inpatient Rehabilitation Facility Services; Outpatient Dialysis Services; and Hospice Services,” there was a draft recommendation specific to inpatient rehabilitation facilities (IRF). The draft recommendation was for fiscal year 2026 and noted that Congress should reduce the 2025 Medicare base payment rate by 7 percent. The PowerPoint presentation is available here.

During this public meeting, MedPAC voted to finalize this recommended payment reduction to fiscal year 2026 IRF Prospective Payment System (PPS) payments. Both AMRPA and other national hospital stakeholders, on behalf of IRFs, strongly opposed this proposed payment cut (prior to the public meeting). However, MedPAC advanced the recommended cut with limited discussion about the potential impacts on patient access and IRF operations.

MedPAC’s recommendations do require Congressional action. As a result, advocacy will be planned to continue to voice concerns with this recommendation. Members will be kept apprised of any upcoming changes.

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The Centers for Medicare and Medicaid Services (CMS) recently notified the American Medical Rehabilitation Providers Association (AMRPA) that the rollout of the Review Choice Demonstration (RCD) would begin on August 21, 2023, in Alabama. In previous information released about the RCD, Pennsylvania is most likely to be one of the next states in line for this rollout. Under this demonstration, CMS Medicare Administrative Contractors (MACs) will review all Medicare Fee-for-Service (FFS) claims in select states. CMS will utilize a dedicated website to provide updated information and resources to inpatient rehabilitation facility (IRF) stakeholders.

RCPA is working closely with AMRPA staff and will keep members apprised of developments and updates throughout the demonstration. The RCD website confirms that affected IRFs will have the option to elect pre-claim or post-payment review (and must use the same option for all claims).

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RCPA has been in communication with the American Medical Rehabilitation Providers Association (AMRPA), who has been working with the Centers for Medicare and Medicaid Services (CMS) to ensure inpatient rehabilitation facilities (IRFs) do not face inappropriate non-compliance penalties related to the IRF Patient Assessment Instrument (PAI) version 4.0 that is set to go into effect tomorrow (October 1, 2022). One particular concern is new items in version 4.0 do not include a “skip logic” to account for unplanned discharges that classify as incomplete stays. This oversight could lead to many IRFs not meeting the 95 percent data completion threshold for the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP).

Yesterday, CMS released a statement on the issue along with a Question & Answer (Q&A) document. CMS also noted that the agency will determine if a permanent fix is necessary and will release any related guidance or data specifications in the coming weeks.

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