UDSMR director responds to rehab reimbursement story
Dear Editor:
I read the cover story of the December 1997 issue of Rehab Continuum Report, which provided readers with an update on rehabilitation reimbursement, including a description of a "dispute" between the Health Care Financing Administra-tion (HCFA) and Uniform Data System for Medical Rehabilitation (UDSMR).
Although comments from four individuals and "rehab insiders" were included in the article, comments from any person at UDSMR were not made available. In order for the readers of your newsletter to be fully and accurately informed, the UDSMR perspective should have been included.
The article reported that "HCFA was unable to completely resolve a dispute with the Uniform Data System for Medical Rehabilitation (UDSMR), which owns the rights to part of the system." The article then states "HCFA could simply throw out the UDS system and opt for something with no strings attached . . . ." and "the dispute between HCFA and the Buffalo-based UDSMR, which claims exclusive rights to some portions of the FIM-FRG, has led some to believe that HCFA will instead mandate a switch to RUGS, giving them a single reimbursement system for post-acute providers."
An individual reading this article is led to believe that HCFA may select a payment system based on the RUGS because the UDSMR has not allowed HCFA to use our proprietary information. This is not an accurate statement.
The original contracts between HCFA and UDSMR were carefully conceived and signed by all parties in October 1995. Conditions of the contract included:
a) allowing HCFA and its contractor (RAND Corp.) full disclosure of UDSMR operations and the FIM-FRG algorithms;
b) conditions covering an evaluation by HCFA for up to 10 years;
c) conditions covering full non-exclusive licensure to HCFA limited to a payment system should HCFA decide to implement FIM-FRG as part of a payment system.
Barbara Wynn, Acting Director of the Bureau of Policy Development, on April 10, 1997 - prior to the release of the HCFA/RAND report - described HCFA's thoughts about a rehabilita- tion prospective payment system. Specifically, she stated, "Rehabilitation patients are treated in several different settings with similar outcomes. Therefore, we believe that an integrated post- acute system offers the best approach. If we were to establish individual payment systems for each type of setting, we are concerned that potentially different incentives inherent in each of the payment systems would influence clinical decisions about the appropriate treatment settings for some patients." This testimony may be found on the HCFA's Web site (www.HCFA.GOV/testimony/ rehab1.htm).
Thus, HCFA had already been considering an integrated post-acute payment system with a single core data assessment tools and classification tool prior to the completion of the HCFA/RAND report. It is important to note that at no time has HCFA made a commitment to use a payment system based on the FIM-FRG system.
Additional pertinent information is as follows:
1. The HCFA/RAND reports were available for release by HCFA on Oct. 17, 1997, and are currently available through the National Technical Information Service.
2. UDSMR has given permission to release the HCFA/RAND reports as drafted except for removal of the CART regression trees and inclusion of a statement related to UDSMR rights according to its contracts with HCFA.
Enclosed is a copy of the statement released in September 1997 UDSMR describing the organization's position on the HCFA/RAND report, including a summary of some of the contract conditions described above. The statement was sent to over 7,000 rehabilitation providers. A copy is enclosed. Also, it may be found on the UDSMR Web site at www.udsmr.org. We ask that you use this material to correct any misinformation.
In future articles updating readers on the rehabilitation payment system, your reporters should provide a full and fair account of the topic by contacting all the involved parties. I would be happy to be the contact person and may be reached at (716) 829-2076, ext. 28. Such a critical issue, which affects rehabilitation patients, clinicians, and facilities, deserves thorough and responsible reporting.
Sincerely,
Carl V. Granger, MD, Director
Uniform Data System for Medical Rehabilitation
[Editor's note: Rehab Continuum Report made at least three telephone calls to staff at the UDS about the FIM-FRG issue and the article mentioned in the above letter. None of the phone calls were returned before the deadline for the issue. RCR subsequently reported in its January 1998 issue that Tom Hoyer of HCFA favors a single reimbursement system for post-acute services.]
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