AHA Comments on Inpatient Rehabilitation Facility Proposed Rule for FY 2022

June 7, 2021

The American Hospital Association (AHA) comments on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2022 proposed rule on the IRF prospective payment system (PPS).

The AHA appreciates CMS’ streamlined proposed rule, which allows IRFs and their partners to continue to focus on local COVID-19 responses. In addition, we continue to appreciate the IRF-related waivers implemented by CMS to optimize the field’s contribution to the national response, both in those communities still experiencing surges, as well as for higher-acuity patients recovering from the virus who require both hospital-level care and intensive rehabilitation to address longer-term clinical after effects. This letter addresses several issues, including the use of claims for active and recovering COVID-19 cases in the annual payment update and several proposed changes related to quality reporting. In addition, this letter responds to the agency’s requests for information related to digital quality reporting and health equity. View the entire letter below.