MedPAC Recommendation on Medicare Site-Neutral Rehabilitation Creates Barriers to Patient Access

Washington, D.C. – March 13, 2015: The Coalition to Preserve Rehabilitation (CPR), which represents leading consumer, disability, and clinician organizations, expressed serious concern over the Medicare Payment Advisory Commission’s (MedPAC’s) recommendation released today to adopt “site-neutral” payment for certain Medicare patients in need of medical rehabilitation following illness or injury. CPR believes the recommendation included in Report to the Congress: Medicare Payment Policy will inappropriately divert patients who need inpatient hospital rehabilitation to less intensive settings such as nursing homes based on their diagnosis alone, and not on their individual, medical or rehabilitation needs.

The MedPAC Report recommends that Inpatient Rehabilitation Hospitals (“IRFs”) and Skilled Nursing Facilities (“SNFs” or nursing homes) receive SNF rates for certain patients with conditions that they assert can be treated in either setting. The policy would apply in 2016 and be phased-in over a three year period. The specific conditions subject to the site-neutral policy would be determined by the Secretary through rulemaking.

“MedPAC’s recommendation on site-neutral post-acute care ignores data demonstrating different outcomes in care provided in different settings,” stated Kim Calder, Director of Health Policy of the National Multiple Sclerosis Society and CPR Steering Committee member. The level of intensity and coordination in rehabilitation hospitals and units is completely different from nursing homes and recent studies have demonstrated significant differences in patient outcomes in these two settings of care.[1]

“By adopting SNF rates for what is actually a higher, hospital level-of-care, this policy would create a strong financial disincentive to serve certain patients.  This will inevitably lead to access problems for medically complex patients who require an intensive, coordinated level of rehabilitation with the 24-hour availability of physicians.  This level of care is simply not available in SNFs,” stated Judy Stein, Executive Director of the Center for Medicare Advocacy and CPR Steering Committee member.

“The site-neutral policy wrongly places cost considerations over the best interest of Medicare beneficiaries,” said Maggie Goldberg, Vice President of Policy and Programs of the Christopher and Dana Reeve Foundation and CPR Steering Committee member. “Any future Congressional consideration of this controversial proposal must consider the long-term impact and unintended costs of diverting beneficiaries away from a setting of care that has been demonstrated to maximize health, function, and independent living.”

“MedPAC asserts that this proposal will result in savings. But without better quality and cost-data across post-acute care settings, we believe this proposal will cost Medicare more in the long run,” stated Susan Connors, President/CEO of the Brain Injury Association of America and CPR Steering Committee member. “As an organization advocating for individuals with brain injuries, we find this proposal to be particularly alarming in terms of the impact on patients.”

The Improving Medicare Post-Acute Care Transformation (IMPACT) Act, which was enacted last year, would collect data across post-acute care setting, enabling policy makers to develop reforms that do not potentially stint on patient care. CPR and its members will continue to encourage Congress to refrain from prematurely implementing a site-neutral payment system before the IMPACT Act data can be collected and analyzed.

“There are ways to reduce the costs of post-acute care without creating access barriers for patients, as the site-neutral policy does. We will be urging Congress to protect access to intensive, coordinated care provided by inpatient rehabilitation hospitals for Medicare beneficiaries,” said Alexandra Bennewith, Vice President, Government Relations for the United Spinal Association and CPR Steering Committee member. “It is critical for Medicare patients to be treated in the settings that will enable them to return to their home, family, work and community in the quickest and most effective way possible.”

The Coalition to Preserve Rehabilitation is a coalition of national consumer and clinical organizations with the goal of preserving access to rehabilitation services. CPR advocates for policies that ensure access to rehabilitative care so that individuals with injuries, illnesses, disabilities, and chronic conditions may regain and/or maintain their maximum level of independent function. CPR’s Steering Committee is composed of the Brain Injury Association of America, the Center for Medicare Advocacy, the National Multiple Sclerosis Society, the Christopher and Dana Reeve Foundation, and United Spinal Association.

[1]“Assessment of Patient Outcomes of Rehabilitative Care Provided in Inpatient Rehabilitation Facilities (IRFs) and After Discharge,” Dobson DaVanzo & Associates, LLC, July 2014, available at http://preserverehab.org/advocacy/promote-study-on-the-importance-of-access-to-inpatient-rehabilitation-care/.