AHA Comment Letter on CMS’ Inpatient Rehabilitation Facility Proposed Payment Rule FY 2025

May 24, 2024

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1804-P
P.O. Box 8016
Baltimore, MD 21244–8016.

Re: Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2025 and Updates to the IRF Quality Reporting Program; 89 Fed. Reg. 22,246 (March 29, 2024).

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 900 inpatient rehabilitation facilities (IRF), and our clinician partners — more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2025 IRF prospective payment system (PPS) proposed rule.

The AHA is appreciative that CMS did not propose any major payment or coverage changes to the IRF PPS; this predictability will be valuable to IRFs as they continue to serve their patients and communities while facing mounting financial pressures. To that end, we continue to be concerned about shortcomings in the annual payment updates for IRFs — in particular, the market basket forecasts and updates. For example, the forecasts on which CMS relies have been consistently under-forecasting cost growth for IRFs. In addition, the actual market basket increases seem to be falling well short of inflation. Therefore, AHA encourages CMS to consider whether adjustments are necessary in its approach to annual market basket updates.

View the detailed letter below.