CHA has submitted additional comments to the Centers for Medicare & Medicaid Services (CMS) about the proposed inpatient rehabilitation facility (IRF) review choice demonstration.
Under the demonstration, IRFs will choose either pre-claim or post-claim review for all claims. Once an IRF reaches a 90% claim approval, it may choose to be released from 100% claim review and will continue to be subject to a spot check of 5% of its claims to ensure continued compliance. CMS proposes to implement the demonstration in Alabama, then expand to California, Pennsylvania, and Texas; a start date for the demonstration has not been announced.
CHA urges CMS to withdraw the proposed demonstration or delay implementation until at least 12 months after the end of the public health emergency. CHA also reiterates previously submitted comments regarding the demonstration, including concerns about administrative burden and demonstration design.