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Washington Highlights

AAMC Submits Comments on Inpatient Rehabilitation Facilities PPS Proposed Rule

June 24, 2011—In a June 21 comment letter  on the fiscal year 2012 inpatient rehabilitation facilities (IRF) prospective payment system (PPS) proposed rule, the AAMC urges the Centers for Medicare and Medicaid Services (CMS) not to make a change to the agency’s methodology for calculating the teaching status adjustment that would result in significant cuts to teaching rehabilitation facilities.

In the proposed rule, CMS announced plans to move from a weighted to an unweighted methodology in the agency’s regression analysis to update the adjustment factors used to calculate the rural, low income percentage (LIP), and teaching status adjustments [see Washington Highlights, April 22]. The result of this methodological change would be a reduction in payments of 3.9 percentage points from FY 2011 to FY 2012 for major teaching IRFs. The AAMC letter encourages CMS to continue using a weighted methodology because a weighted regression, in which IRFs with more cases are given more weight than IRFs with fewer cases, provides a more accurate and fairer estimate than an unweighted regression, where all IRFs regardless of size are equally weighted. 

Additionally, the AAMC applauds CMS for its proposal to give a temporary resident cap increase to those teaching IRFs that take on displaced residents from closed IRFs or closed IRF residency programs. The AAMC letter encourages CMS to refine the new policy, however, so that it applies not only to IRFs training-displaced residents from IRFs and programs that closed after Oct. 1, 2011, but to any IRF training-displaced residents as of that date. The AAMC also urges CMS to work with Congress to provide for a permanent distribution of IRF resident caps for IRFs that close.


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Senior Legislative Analyst, Govt. Relations
Telephone: 202-903-0806