The American Medical Rehabilitation Providers Association’s
(AMRPA’s) Statement on the HHS Office of the Inspector General
(OIG) Report “Adverse Events in Rehabilitation Hospitals: National
Incidence Among Medicare Beneficiaries”
July 22, 2016
AMRPA welcomes any studies that shine a light on opportunities to improve
health care delivery. We have focused on quality and safety for many years,
through a wide range of initiatives and programs. AMRPA’s members are
dedicated to providing the highest quality care and optimal outcomes to the
patients they serve and embrace greater collaboration with the Centers for
Medicare and Medicaid Services (CMS) to achieve these goals.
The OIG’s findings reflect the need to look at health outcomes through a
different lens – to reduce avoidable adverse events, we must focus on
systemic causes that pervade the entire health care system rather than
individual providers in isolation. Although measures and assessments vary
across different acute and post-acute care settings, and it is impossible to
draw apples-to-apples comparisons between hospital and nonhospital
providers, the result of this and related OIG studies reveal consistent levels
of adverse events across different provider types and care settings.
Rehab Industry has Made Substantial Strides to Increase Hospital
Quality Since 2012 Report Period
It is also critical to note that significant changes have occurred in
rehabilitation hospitals to advance quality, prevent hospital readmissions,
reduce medical errors, and improve safety since the limited study period in
2012, including the implementation of a Medicare quality program, revised
Joint Commission standards, and other quality and operational initiatives
generally designed to instill a culture of safety. Even in retrospect,
reviewers characterized only 8 percent of adverse events as “clearly
preventable” and the majority as “not preventable.” Compared to a robust
and expanding quality measurement program being implemented in real
time by providers, a post hoc review with the benefit of hindsight has
limited application to those providing care in the moment, who do not have
unlimited time to second guess with the benefit of information about the
future.
Regardless of limitations of the OIG’s methodology, there is consensus
about the opportunities to reduce medical errors and the need to

 continually strive for quality improvement. To deliver the most error-free
delivery system possible, however, we need to build in more safeguards
than our current policies allow. Market and regulatory pressures from
payers place an ever-growing emphasis on documentation management
processes that divert scarce resources away from patient care.
Regulatory Pressures Limit Providers Ability to Focus on Patient
Care
The pressures placed on providers, patients, and families to accelerate the
pace of care delivery, speed care transitions, and to press patients into less
expensive settings all contribute to our system a sense of urgency that is
counter to the need to take time to do things right the first time, and to
allow caregivers and patients to have continuity of care provided not just by
documentation, but by caregivers who develop relationships with patients
and can rely on their personal knowledge, history, and experience with each
individual patient to minimize the risk of harm being done by inaction or
inattention.
AMRPA concurs in the OIG’s recommendations and embraces CMS’
continued engagement on information and data sharing to support qualitycentric reforms. We remain focused on improving the safety and quality of
care of the health system in this country and providing individuals that visit
our hospitals with superior, patient-centric care.
About the American Medical Rehabilitation Providers Association
AMRPA is the nation’s only trade organization dedicated solely to the
interests of Inpatient Rehabilitation Hospitals and Units (IRH/U), outpatient
rehabilitation centers and other medical rehabilitation providers. Our focus
is on collective advocacy--working together to advance the field of medical
rehabilitation and support the medical rehabilitation needs of persons with
disabilities. For more information, please visit www.amrpa.org.