ARN Advocates for Rehabilitation Nursing in IRF Payment Reform

The Association of Rehabilitation Nurses (ARN) is actively representing the rehabilitation nursing perspective as the Centers for Medicare & Medicaid Services (CMS) explores potential changes to the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS).

CMS and its contractors are evaluating concepts that could change how patients are classified and how payment is determined for inpatient rehabilitation care. These include approaches that place greater emphasis on diagnosis and medical complexity. ARN has been engaged in stakeholder discussions and preparations surrounding the CMS Technical Expert Panel (TEP) reviewing these concepts.

ARN supports thoughtful modernization of the IRF payment system when it is clinically sound, transparent, supported by evidence, and reflects how rehabilitation care is actually delivered. However, ARN does not support the current payment reform concepts in their present form because they do not yet adequately reflect the clinical realities of inpatient rehabilitation or the factors that drive the intensity and complexity of rehabilitation care.

A central concern is ensuring that diagnosis is considered in the appropriate context. The diagnosis associated with a patient's acute hospitalization may not fully represent why that individual requires inpatient rehabilitation. ARN believes a future payment methodology must continue to recognize the patient's rehabilitation impairment and functional and cognitive status while also appropriately considering diagnosis and cumulative medical complexity.

ARN is also emphasizing the essential role of 24-hour rehabilitation nursing. Rehabilitation nursing resource needs are influenced by factors that may not be captured through diagnosis alone, including cognition and behavior, supervision and safety needs, bowel and bladder management, skin integrity, medication complexity, patient and caregiver education, and preparation for a safe transition to the community.

ARN believes these clinical characteristics should be considered as CMS evaluates future payment methodologies so that rehabilitation nursing is recognized as an essential component of achieving patient outcomes, rather than viewed simply as a staffing or operating cost.

ARN has also encouraged CMS to look beyond a payment model's ability to predict costs. Any future methodology should be evaluated for its potential impact on patient access to inpatient rehabilitation, functional outcomes, nursing-sensitive outcomes, caregiver readiness, safe community discharge, and unintended incentives that could influence which patients IRFs are able to serve.