• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to footer
  • Donate Now
  • Sign up for CMA’s weekly newsletter!

Center for Medicare Advocacy

Advancing Access to Medicare and Healthcare

  • Eligibility/Enrollment
  • Coverage/Appeals
    • Medicare Costs
    • Self Help Materials – Toolkits & More
  • Topics
    • Basic Introduction to Medicare
    • Medicare Costs
    • Home Health Care
    • Improvement Standard and Jimmo News
    • Nursing Home / Skilled Nursing Facility Care
    • Outpatient Observation Status
    • Part B
    • Part D / Prescription Drug Benefits
    • Medicare for People Under 65
    • Medicare “Reform”
    • All Other Topics
    • Resources
      • Infographics
  • Publications
    • CMA Alerts
    • Fact Sheets & Issue Briefs
    • Infographics
    • The Medicare Handbook
    • SNF Enforcement Newsletter
    • Elder Justice Newsletter
    • Medicare Facts & Fiction
    • Articles by Topic
  • Litigation
    • Litigation News
    • Cases
    • Litigation Archive
    • Amicus Curiae Activities
  • Newsroom
    • Press Releases
    • Editorials & Letters to the Editor
    • CMA Comments, Responses, and Letters
    • CMA in the News
  • About Us
    • National Voices of Medicare Summit
    • Mission Statement
    • CMA FAQs
    • CMA Annual Impact Report
    • Personnel & Boards
    • The Center for Medicare Advocacy Founder’s Circle
    • Connecticut Dually Eligible Appeals Project
    • Community Outreach and Education Project (COEP)
    • National Medicare Advocates Alliance
    • CMA Webinars
    • Products & Services
    • Testimonials
    • Career, Fellowship & Internship Opportunities
    • Contact Us
  • Support Our Work
    • Donate Now
    • Build a Legacy with CMA
    • Join the Center for Medicare Advocacy Founder’s Circle
    • Take Action
    • Share Your Health Care Story
    • Tell Congress to Protect Our Care
    • Listen to Medicare & Health Care Stories
    • Sign up for CMA’s weekly newsletter!

Site Neutral Payment for Rehab. Care

Print Friendly, PDF & Email

What is "Site Neutral Payment?"

Site Neutral Payment is the concept of paying the same amount for rehabilitation regardless of whether the patient is treated in an inpatient rehabilitation hospital or nursing home.

Problems with Site Neutral Payments for Rehabilitation

  • Vulnerable Medicare beneficiaries risk being diverted into a less intensive, less appropriate rehabilitation setting simply because it is less expensive.
  • The rationale is that the daily cost of care in the nursing home is lower than the hospital, and that the care is the same.  But this is not true. Inpatient rehabilitation facilities (IRFs) offer more intensive, coordinated treatment, better results, and fewer risks of adverse outcomes (see below).
  • Site neutral payments would result in patients who need intensive inpatient rehabilitation being diverted inappropriately to less intensive settings based solely on their diagnosis, despite their clinical needs. This is clearly a mistake, and could endanger vulnerable beneficiaries.

Nursing Homes and Rehabilitation Hospitals are NOT the Same

  • Rehabilitation hospitals and nursing homes are not the same and should not be treated as such by MedPAC, Congress or the Medicare program.
  • Rehabilitation hospitals must meet stringent criteria to be licensed as a hospital and follow specific regulations that govern the required intensity, multi-disciplinary therpaies, and coordination of rehabilitation services. Physicians must manage IRF care, and must be available 24-hours per day.
  • Conversely, there are few regulations that set standards for how or what rehabilitation is provided in nursing homes. Physicians and coordinated multi-disciplinary care are not available daily, 24-hours per day.
  • MedPAC acknowledges these differences, stating that rehabilitation hospitals have more extensive requirements regarding the amount of therapy and physician supervision of their patients.

IRFs v. SNFs – Significant Differences in Patient Outcomes

  • Patients treated in inpatient rehabilitation hospitals have better outcomes, go home earlier and live longer than similar patients treated in nursing homes, according to a 2014 study by Dobson DaVanzo & Associates, LLC.
  • Across all 13 conditions examined in this Study, including some of those being proposed for Site Neutral payments, patients treated in nursing homes have more emergency room visits, are readmitted to hospitals more often, and have an increased risk of death compared to clinically similar patients treated in rehabilitation hospitals.
  • This study demonstrates the risks of denying Medicare patients the IRF care they need.

What Should be Done?

  • All Medicare policies should ensure patients receive individualized assessments of their need for care, including for the intensive, coordinated rehabilitation provided only by IRFs.
  • Congress should ensure that MedPAC and Medicare policies do not override individualized, clinical judgment regarding where a patient should receive care.
  • Medicare policies should be evidence-based and use comparable data.
  • Post-acute reforms should not be implemented before the recently enacted "IMPACT Act," which, for the first time, will provide a chance to analyze comparable data on patient outcomes across different settings of post-acute care. Without comparable data, policy makers are left making decisions on payment reform based on cost alone, without the ability to truly consider patient care and outcomes

The Center for Medicare Advocacy is a member of the Coalition to Preserve Rehabilitation (CPR), a coalition of national consumer, clinician and membership 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.


Articles and Updates

  • CMS Proposed Rule to Redefine Group Therapy in Skilled Nursing Facilities: Concern for Resident Care April 25, 2019
  • Value of Inpatient Rehabilitation Hospital Care Reaffirmed May 18, 2016
  • Bundling Payments for Post-Acute Care May 14, 2015
  • Center for Medicare Advocacy Opposes Site-Neutral Payment Recommendation December 19, 2014
  • No Site Neutral Payments for Inpatient Rehabilitation Facilities and Skilled Nursing Facilities December 11, 2014
  • Center for Medicare Advocacy Joins Leading Consumer and Clinician Organizations Critical of Attempts to Divert Medicare Patients From Rehabilitation Hospitals to Nursing Homes December 11, 2014
  • Inpatient Rehabilitation Facilities and Skilled Nursing facilities: Vive La Difference! July 31, 2014

Primary Sidebar

Easy Access to Understanding Medicare

The Center for Medicare Advocacy produces a range of informative materials on Medicare-related topics.
Sign Up for CMA's Free Newsletter
Register for CMA's Free Webinars

  • Medicare Basics
  • Medicare Reform
  • CMA Alerts
  • Fact Sheets & Issue Briefs
  • CMA Webinars
  • Connecticut Info & Projects
  • Health Care Stories
  • Se habla Español

Jimmo v. Sebelius

Medicare covers skilled care to maintain or slow decline as well as to improve.

Improvement Isn’t Required. It’s the law!

Read more.

National Voices of Medicare Summit

With the many threats currently facing the Medicare program, now is the time to come together as allies and explore ways to advocate for comprehensive Medicare coverage, health equity, and quality health care. Drawing inspiration from real-life experiences and stories of beneficiaries and caregivers, we hope to share impactful discussions with you.

Learn more.

Center for Medicare Advocacy Follow 10,567 5,345

A national nonpartisan, nonprofit law organization working to advance access to comprehensive #Medicare coverage and quality #healthcare.

CMAorg
CMAorg avatar Center for Medicare Advocacy @CMAorg ·
14h 2052762406430859515

What does it mean to age well in America?

Join a free May 21 virtual screening of Aging in America: Survive or Thrive, the PBS documentary narrated by Martin Sheen and supported by our friends at @johnahartford.

The film explores aging, caregiving, ageism, affordability, and

Reply on Twitter 2052762406430859515 Retweet on Twitter 2052762406430859515 0 Like on Twitter 2052762406430859515 0 X 2052762406430859515
Retweet on Twitter Center for Medicare Advocacy Retweeted
alsadvocacy avatar ALS Advocacy @alsadvocacy ·
7 May 2052310376113492253

Image for twitter card

Glial cells reveal why some ALS cases progress slowly over decades

The core facilities of the Cibio Department of the University of Trento have all taken part in a study on amyo...

medicalxpress.com

Reply on Twitter 2052310376113492253 Retweet on Twitter 2052310376113492253 2 Like on Twitter 2052310376113492253 2 X 2052310376113492253
CMAorg avatar Center for Medicare Advocacy @CMAorg ·
5 May 2051770699463700891

Register free:
https://medicareadvocacy.org/summit-2026/?utm_source=twitter&utm_medium=organic_social&utm_campaign=summit_2026&utm_content=may5_speaker_spotlight
⠀
From advocacy, to policy, to on-the-ground beneficiary support, the Medicare landscape is shifting in important ways.
⠀
Join Martin O’Malley, Natalie Kean, Kata Kertesz, and other national experts on May 20 from 12p-430p ET for CMA’s

Reply on Twitter 2051770699463700891 Retweet on Twitter 2051770699463700891 0 Like on Twitter 2051770699463700891 0 X 2051770699463700891
CMAorg avatar Center for Medicare Advocacy @CMAorg ·
5 May 2051673303920587024

What do you think about the future of AI in healthcare? There are many promising opportunities, and also some challenges like the WISeR Model, so we're curious to know your thoughts.

Thank you @finksta and @StudyFindsorg for the beautifully written and insightful article!

Doug Kelly @dougkelly

Artificial intelligence (AI) is rapidly transforming healthcare. From accelerating disease cures to increasing transparency, AI is helping patients and doctors achieve better outcomes.

Now, a new major Harvard and Stanford study finds that AI outperforms doctors at diagnosing

Reply on Twitter 2051673303920587024 Retweet on Twitter 2051673303920587024 1 Like on Twitter 2051673303920587024 1 X 2051673303920587024
Load More

Footer

Stay Connected:

  • Contact Us
  • Sitemap
  • Products & Services
  • Copyright/Privacy

© 2026 · Center for Medicare Advocacy