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Concerns about the threat to patients raised in a letter to MedPAC and testimony before the House Energy and Commerce Health Subcommittee

Washington, D.C. – The Coalition to Preserve Rehabilitation (CPR), which represents leading consumer and clinician organizations, today raised serious concerns with proposals that would divert patients who need intensive inpatient hospital rehabilitation to less intensive settings based on diagnosis, despite their clinical needs. This concept, which would equalize payments between rehabilitation hospitals and nursing homes for certain conditions, is often referred to as “site-neutral” payment.

CPR submitted a letter to the Medicare Payment Advisory Committee (MedPAC), which is set to recommend this policy approach to Congress later this month, and provided written testimony to the House Energy and Commerce Health Subcommittee, which is holding a hearing today with the executive director of MedPAC. CPR argues it would be a mistake to put cost considerations before the clinical needs of patients.

“Site-neutral proposals are based on a false premise that inpatient rehabilitation hospitals and nursing homes provide the same level of rehabilitation care,” stated Susan H. Connors, president and CEO of the Brain Injury Association of America, and CPR member. “While I appreciate that MedPAC is trying to save money, it should not do so at the expense of vulnerable Medicare beneficiaries who may be denied the intensive and coordinated hospital-level rehabilitation care they need.”

In its letter and testimony, CPR argues that a decision on site-neutral should be delayed until more data is available to examine what the impact will be on patients.

“The theory of site-neutral payments is simply untested and not evidence based,” said Susan Stout, president and CEO of the Amputee Coalition, and CPR member. “Post-acute care reforms should not precede implementation of the IMPACT Act, which was enacted this Summer and will finally provide a chance to analyze comparable data on patient outcomes across different settings. The proposed reform also seems to ignore the most comprehensive study to date that shows patients treated in rehabilitation hospitals have better outcomes, go home earlier and live longer than similar patients treated in nursing homes, including some of those proposed for site-neutral payments.”

While MedPAC is set to vote later this month on its site-neutral proposal, the commission has not publicly released a list of the 17 conditions affected by this policy.

“I’m very concerned about MedPAC’s lack of transparency in its rush to approve a site-neutral payment recommendation. A decision that threatens so many Medicare beneficiaries should not be brokered behind closed doors,” said Judith A. Stein, executive director of the Center for Medicare Advocacy. “To make matters worse, MedPAC is not expected to seek public comment on this proposal at their December meeting until after the vote is scheduled to occur.”

Additional background information on site-neutral payments for post-acute care can be found here.

For more information, contact Lauren Weybrew 646-214-0514 or

The Coalition to Preserve Rehabilitation is a coalition of national consumer and clinical organizations with the goal of preserving access to rehabilitation services. CPR advocates for policies that ensure access to rehabilitative care so that individuals with injuries, illnesses, disabilities, and chronic conditions may regain and/or maintain their maximum level of independent function.

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