CA

Subject Line: File Code CMS–1538–P My name is Carolyn Webb and I am a board certified music therapist providing services in the Santa Barbara area for those individuals with Alzheimer's Disease and other neurological deficiencies. Thank you for the opportunity to submit comments regarding the FY 2010 Payment and Policy Updates for Inpatient Rehabilitation Facilities. I appreciate the proposed clarification on patient selection and the attention to quality care for individuals in need of IRF treatment. It is in direct response to the provision of quality therapeutic services that I request the following revisions: §412.29 (a) Current Proposed Language: Provide rehabilitation nursing, physical therapy, occupational therapy, plus, as needed, speech- language pathology, social services, psychological services, and prosthetic and orthotic services that— Requested Language: Provide rehabilitation nursing, physical therapy, occupational therapy, plus, as needed, speech- language pathology, social services, psychological services, prosthetic and orthotic services, and other skilled rehabilitative therapies that— §412.29 (a) (2) Current Proposed Language: Require the care of skilled professionals, such as rehabilitation nurses, physical therapists, occupational therapists, speech language pathologists, prosthetists, orthotists, and neuropsychologists. Requested Language: Require the care of skilled professionals, such as rehabilitation nurses, physical therapists, occupational therapists, speech language pathologists, prosthetists, orthotists, neuropsychologists, and other rehabilitation therapists. §412.29 (b) (1) (i) Current Proposed Language: Requires the active and ongoing therapeutic intervention of at least two therapy disciplines (physical therapy, occupational therapy, speech-language pathology, or prosthetics/ orthotics therapy), one of which must be physical or occupational therapy. Requested Language: Requires the active and ongoing therapeutic intervention of at least two therapy disciplines (physical therapy, occupational therapy, speech-language pathology, prosthetics/ orthotics therapy, or other skilled rehabilitative therapies), one of which must be physical or occupational therapy. §412.29 (b) (1) (ii) Current Proposed Language: Generally requires and can reasonably be expected to actively participate in at least 3 hours of therapy (physical therapy, occupational therapy, speech-language pathology, or prosthetics/ orthotics therapy)… Requested Language: Generally requires and can reasonably be expected to actively participate in at least 3 hours of therapy (physical therapy, occupational therapy, speech-language pathology, prosthetics/ orthotics therapy or other skilled rehabilitative therapies)… Rationale: The current proposed language would restrict access to other skilled rehabilitative therapies commonly provided in IRFs. The requested language allows IRFs to provide a full range of evidenced based rehabilitative services, including music therapy. Research demonstrates that music therapy can directly enhance motor, cognitive, verbal, and/or social/emotional functioning, providing effective treatment strategies for the IRF. The perception of temporal, force, and spatial aspects inherent in music, has been shown to shape subsequent brain and behavior functioning. Music, specifically rhythm, has been shown to have a significant effect on the central nervous system (CNS) and current research and evidence-based clinical practice provide outcomes which reflect the therapeutic significance of this effect. The requested language would permit access to this and other skilled rehabilitation therapy services. Thank you for your consideration of these requested language revisions. Sincerely, Carolyn A. Webb, MT-BC Music Therapist-Board Certified Fellow, Academy of Neurologic Music Therapy 5142-B Foothill Rd. Carpinteria, CA 93013 carolynwebb@earthlink.net 214-923-2477