Coalition to Preserve Rehabilitation Requests CMS Withdraw Demonstration Project Proposal for Inpatient Rehabilitation Facilities

Proposed demonstration project could have a negative effect on people with certain conditions, such as stroke, traumatic brain injury, and spinal cord injury.

The Coalition to Preserve Rehabilitation (CPR) released a comment letter urging the Centers for Medicare and Medicaid Services (CMS) to withdraw a demonstration project proposal for inpatient rehabilitation facilities (IRFs) that would subject all IRFs in certain states to 100% pre-claim or post-payment review for all Medicare patients admitted to this level of care. According to CPR, this proposal poses a serious risk of restricting patient access to care.

“This policy is severely misguided and would further restrict access to inpatient rehabilitation care for which Medicare beneficiaries are eligible and cannot obtain in another setting,” said Judith Stein, executive director of the Center for Medicare Advocacy. “For too long CMS has focused on concerns of overutilization, and not on the myriad circumstances when patients are unable to get the necessary care for which they qualify. It’s time barriers to necessary care are monitored and reviewed. Unfortunately, this demonstration project would make it more difficult for some of Medicare’s most vulnerable patients to gain access to appropriate care, especially care to enable them to maintain their function and prevent or slow their decline.”

According to CPR, historical trends relating to denials suggest that this proposal would result in a significant increase in denied IRF cases, forcing rehabilitation facilities to narrow their patient admission criteria against their own physicians’ medical judgment. Further, they argue that the impact of the demonstration would extend beyond IRFs. Patients denied care at IRFs would likely need to pursue care in settings that cannot provide the same level of intensive care available in an IRF, risking worse outcomes and exacerbating caregiver shortages through the influx of patients to inappropriate care settings.

“The RCD would have a major, disparate impact particularly on people with disabilities and chronic conditions, running counter to the Biden Administration’s explicit policy to advance equity for underserved populations,” said Susan Connors, president and CEO of the Brain Injury Association of America, in the release. “The greatest impact of the proposed demonstration would fall on people with certain conditions, such as stroke, traumatic brain injury, spinal cord injury, and debility, and decrease their chances of living independently in their homes and communities.”


Coalition to Preserve Rehabilitation calls for CMS to withdraw proposed review “choice” demonstration for inpatient rehabilitation hospitals [news release]. Coalition to Preserve Rehabilitation; October 14, 2021. Accessed October 19, 2021.

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