Re: File Code CMS-1729-P
Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for
Federal Fiscal Year 2021 Proposal to Allow Non-physician Practitioners to Perform
Certain IRF Coverage Requirements that Are Currently Required to Be Performed by a
Rehabilitation Physician
Dear Administrator Verma:
The undersigned organizations write in response to a proposal included in the Fiscal Year (FY) 2021
Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) proposed rule. In this rule,
the Centers for Medicare and Medicaid Services (CMS) proposes to amend regulations to allow the
use of non-physician practitioners (NPPs) to perform the IRF services and documentation
requirements currently required to be performed by rehabilitation physicians under 42 CFR §
412.622. As representatives of the patients who require high-quality IRF-level care, as well as the
clinicians and institutions that furnish services to the broader Medicare population, the undersigned
organizations write to express our concerns that this proposal will undermine delivery of and access
to physician-led team-based care in the IRF setting, which is critical for both ensuring the health and
safety of patients receiving specialized rehabilitation care and differentiating the services that IRFs
provide. We also are concerned that this sets a dangerous precedent for removing physician
supervision requirements across all health care settings. For the reasons we further outline below,
we strongly oppose this proposal to expand the scope of services NPPs furnish in IRFs, and we
urge CMS to uphold the role of the rehabilitation physician in delivering and overseeing care for
patients in IRF settings.
Read full letter here
