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Opinion: Proposed Rehab Rule Would Put Patient Care at Risk

August 3, 2020

The below Letter to the Editor was written by BIAA President/CEO Susan Connors on behalf of the Coalition to Preserve Rehabilitation. It was published August 1, 2020 in Modern Healthcare.

In June, Modern Healthcare wrote about an upcoming payment rule for inpatient rehabilitation hospitals and units, commonly referred to as “IRFs,” which portrayed a controversial Medicare proposal to allow non-physician practitioners (physician assistants and nurse practitioners) to perform the services currently provided by rehabilitation physicians in IRFs as a “turf war” between provider groups. However, this completely omits the voice of a third group with strong views on this issue – patients.

If finalized as proposed, this rule could put patients at serious risk. Patients typically arrive in IRFs in crisis, following severe illness or injury and in need of intensive rehabilitative care and medical management. They entrust their lives to IRFs to restore their health and function. Medicare patients defer to IRF providers because they assume the federal rules governing these hospitals justify their trust in their provider. This trust is violated when non-physician practitioners replace rehabilitation physicians in making major IRF care decisions.

IRFs are not skilled nursing facilities. They provide hospital-level care. IRFs treat some of the most complex Medicare patients, many with severe injuries or illnesses and multiple comorbidities. The rehabilitation teams in IRFs are led by highly trained physicians, typically with board certification and long-term, specialized experience in medical rehabilitation.

The patients our organizations represent have serious, often lifelong conditions such as brain injury, spinal cord injury, and multiple sclerosis, requiring the highest quality of treatment. IRF care can set the stage for a lifetime of health and function rather than disability. Allowing this care to be solely provided by non-physicians without specific training in rehabilitation could have dire consequences for the patients we represent. We believe rehabilitation physicians must retain the role of directing IRF care to ensure that IRF patients receive the expert treatment they need and deserve.

The Coalition to Preserve Rehabilitation (CPR) is a coalition of 55 national organizations that represent patients – and the clinicians who serve them – who are frequently in need of the intensive level of medical rehabilitation services provided in IRFs.

This Letter to the Editor was written in response to Physicians, non-physicians at odds over inpatient rehab rule, published June 16, 2020.