Beneficiary and Clinical Groups Oppose MedPAC’s Site-Neutral Post-Acute Care Payment Recommendation

Washington, D.C. – January 15, 2015: The Coalition to Preserve Rehabilitation (CPR), which represents leading consumer, disability, and clinician organizations, expressed disappointment over the recommendation approved today by the Medicare Payment Advisory Commission (MedPAC) to recommend “site-neutral” payment for certain Medicare patients in need of medical rehabilitation following injury or illness. The coalition believes this policy will inappropriately divert patients who need inpatient hospital rehabilitation to less intensive settings such as nursing homes based on their diagnosis alone, not based on their individual medical and rehabilitation needs.

In December, CPR sent a letter to MedPAC, submitted testimony to Congress, and issued two press releases raising serious concerns with MedPAC’s proposal on site-neutrality between inpatient rehabilitation hospitals (IRFs) and skilled nursing facilities (SNFs). CPR sent a second letter to MedPAC earlier this month. These concerns and recommendations were not meaningfully addressed by the Commission before the MedPAC vote.

“Site-neutral payments are a penny-wise, pound-foolish approach, prioritizing short-term cost considerations over long-term patient outcomes,” stated Maggie Goldberg, Vice President of Policy and Programs at Christopher & Dana Reeve Foundation, and CPR member. “MedPAC fails to consider the long-term patient impact of diverting beneficiaries into less intensive rehabilitation settings despite their clinical needs.”

The IMPACT Act calls on the Centers for Medicare & Medicaid Services (CMS) to develop a uniform data set across all settings of post-acute care. “MedPAC’s mandate includes advising Congress on both cost and quality aspects of Medicare,” stated Judith Stein, Executive Director of the Center for Medicare Advocacy, and CPR member. “MedPAC’s site-neutral recommendation does not promote quality and is, at best, premature.  Congress recognized that further data collection is necessary when it passed the IMPACT Act last fall; that work should be completed before any further action on this proposal is taken.”

“We are also disappointed with the lack of transparency MedPAC exhibited in developing this recommendation,” stated Kim Calder, Director of Health Policy at the National Multiple Sclerosis Society, and CPR member. “MedPAC only recently disclosed the twenty-two conditions proposed for site-neutral payments to the public, which limited the opportunity for timely public analysis and comment. In fact, MedPAC had the list of twenty-two conditions available at December’s public meeting, but chose not to distribute it until after the meeting concluded.”

“Rehabilitation physicians and other clinicians have examined the 22 conditions affected by this policy and are alarmed by the failure to recognize patients with comorbid conditions or complications,” stated Sue Stout, Executive Director of the Amputee Coalition. “Not all SNFs offer the same level of care, and with minimal SNF regulations in place, expert opinion by clinicians suggests that amputees and other patients on the list may be placed at risk under this site-neutral proposal,” she said.

It will now be up to Congress whether to adopt MedPAC’s site-neutral payment recommendation. CPR believes that MedPAC’s recommendation is a clear overreach and under-calculation of the real impact on patients.

“CPR will continue to engage in advocacy efforts that will make sure Congress understands the risk patients will face if payments are equalized between inpatient rehabilitation hospitals and nursing homes for certain conditions,” said Alexandra Bennewith, Vice President of Government Relations at the United Spinal Association, and CPR member. “We will continue to educate lawmakers about how patients in inpatient rehabilitation hospitals with a variety of conditions have better outcomes, go home earlier and live longer than similar patients treated in nursing homes.”

Additional background information on site-neutral payments for post-acute care can be found here and here.

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.