BRB Consulting is pleased to share an expansion of our services. Recognizing the ever-changing financial and regulatory environment in which  today’s rehab and social service providers function, we are adding a unique solution.

We now offer a comprehensive product to support corporate planning, human capital management and business inefficiencies.  Through a coordinated analysis, our team  has discovered methods to improve these areas. The most exciting aspect of this – sometimes the benefits can  occur without spending any additional dollars!

Intrigued?  Great!

We’ll be sharing more about the process in our next blog. But if you can’t wait, give us a call or contact us directly to learn more.  Stay tuned!


The power of the people...clearly this change from CMS reflects what is right with the world- okay maybe not the whole world, but certainly the World of Rehab!  After extensive communication and outreach by numerous professional organizations including AMRPA, APTA, AOTA and more,  CMS recognized some of the inherent problems with  Transmittal 72.  After significant efforts from the  Rehab community and individuals who would be effected by the suggested change, CMS listened!

On February 17, 2012 , CMS rescinded the information and implemented the language below.

Orders for outpatient services (as well as patient referrals for hospital outpatient services) may be made by any practitioner who is:

  • Responsible for the care of the patient;
  • Licensed in, or holds a license recognized in the jurisdiction where he/she sees the patient;
  • Acting within his/her scope of practice under State law; and
  • Authorized by the medical staff to order the applicable outpatient services under a written hospital policy that is approved by the governing body. This includes both practitioners who are on the hospital medical staff and who hold medical staff privileges that include ordering the services, as well as other practitioners who are not on the hospital medical staff, but who satisfy the hospital’s policies for ordering applicable outpatient services and for referring patients for hospital outpatient services.

The CMS Memo on Hospital Outpatient Rehab – February 17 2012 (click to view PDF version) supersedes the guidance for §482.56(b) (Tag A-1132) and §482.57(b)(3) (Tag A-1163) found in SC-11-28 (May 13, 2011) and State Operations Manual (SOM) Transmittal #72 (November 18, 2011).

The new guidance evidences the importance of access and that quality care remain principals upon which CMS seeks to ensure the delivery of provider services.  This  revised language reinforces  these concepts, assuring ongoing rights  for individuals in need of rehab.

As providers and recipients of care,  it is reassuring to know- that with enough coordinated efforts,  change can and  does happen – even in CMS.

Way to go Rehab!

To learn more about managing change in your organization,
contact BRB Consulting today.


As 2012 begins,  everyday life seems to be getting more complicated.  Not only have the political  campaigns taken hold  of the airwaves-yes there is an election in 9 months;  the weather has many of us trying to choose  between shorts and parkas;  and as part of the regular day-to-day quality care practices,  Rehab providers strive to deliver optimal care in this increasingly complex environment. This month’s topic focuses on one of  CMS’s newly revised regulations designed to “improve service delivery”.

Sometimes- new  revisions  simply DO NOT  appear to that.

For example,  CMS  Transmittal 72 11182011 was released in November 2011 under no special circumstances or with any requests for comments. The transmittal  states that all orders for rehabilitation therapies both inpatient  and outpatient must be written by a practitioner aka doctor or nurse practitioner  who is a part of the  hospital staff where the patient is to be treated.  On inpatient- this is not a big deal. It actually  works, when patients receive care in a hospital,  every doctor  who delivers care in that space is a part of  the staff.  Even if the patient came from another state, that new patient will  become  part of the admitting doctor’s service and be under her care for orders.

BUT on outpatient, the interpretation and implementation of this transmittal can be  VERY BIG deal…so let’s consider a real life situation  and analyze that.

For a patient who has received special hospitalization in other city, county or even state, the special therapy orders written  by the discharging doctor  would not be valid at the patient’s local hospital. Like a person who suffers a spinal cord injury while driving from SC to Florida,  is injured in Atlanta and receives care at the special rehab spinal cord center in Georgia.

Once the discharge plans were set,  the patient going back home to SC would have to see the  hospital staff doctor in SC to get new orders to be treated at the local hospital in his hometown town.  Probably- not too quickly either- you know how long it can take to get a non-emergency appointment….plus there is that additional financial cost of co-payments  plus  the real effort for  the patient and family in arranging an additional trip to the new “hospital” doctor.  Clinically, the first doctor knew the patient and his history and wrote the outpatient treatment orders based on those needs;  but the new doctor must start at the beginning….maybe giving similar orders- BUT may not.

Maintaining  quality care and improving access are concepts regularly stated by CMS.   We are just not sure this transmittal’s regulations meets those two goals…what do you think?

AMPRA is actively monitoring the next steps from CMS and the  response from the Rehab industry on Transmittal 72111802011.  If your organization has  have you been affected by this practice – Please contact AMPRA.

Looking to learn more about regulations, quality care and how to positively  impact  your organization- BRB Consulting would welcome hearing from you. Contact us today.


Where does time go?  It’s hard to believe that 2012 will be here in just two weeks.  The year has held numerous challenges for rehabilitation providers. These may have been in the  form of funding issues, staffing issues or even in a clinical nature.

For some of us, there were challenges of a personal nature. Yet, part of the beauty of rehabilitation is the hope that it inspires.  As you look to begin the next year, consider the projects that need to be done, the opportunities for improvement that need to be addressed, and take a deep breath.

Taking first things first, start thinking about the plan.  Then consider activities that need to occur to achieve the goals.  Maybe it’s  time to start thinking about CARF, or quality improvement plans or alternative staffing patterns.  Over the last couple of months, we have offered several ideas for planning in previous blogs.  We’ll be  happy to talk with you to develop a specialized approach for your organization-feel free to contact us anytime for a free consultation.

BRB Consulting thanks our clients, our associates and our friends for a great 2011.

We wish you and yours a happy and healthy new year!

With Thanksgiving being just  a day away, Inpatient Rehabilitation Facilities  (IRFs) are working hard to keep supporting patients needing rehabilitative care.  Clearly  the value of rehab can be seen by Representative Giffords' remarkable progress.  The recent ABC special highlights those successes.   However, there continue to be legislative efforts which will ultimately reduce access to rehab care. Many IRF programs are concerned about their future ability to provide rehab to the community.  Visit AMRPA to learn more about what you can do to keep rehabilitation a right for all people.

Even with these funding cuts on the horizon, IRFs strive to optimize  quality care. Next Tuesday CMS is hosting a special forum.  Everyone is welcome to join the call…

If your organization delivers IRF care,  plan to listen in-the new measures will be discussed. (No registration is needed.)

Special Open Door Forum: Inpatient Rehabilitation Facility
Quality Reporting Program (QRP)
Tuesday, November 29, 2011
2:00 pm – 4:00 pm ET
Dial: 1-800-837-1935
Reference Conference ID: 21834666.

The Centers for Medicare and Medicaid Service (CMS) has scheduled a call that will give an overview of the IRF QRP ( , review of the Affordable Care Act Section 3004 (b) and the Quality Reporting Program for IRFs, and quality measures for the IRF QRP. Questions and comments can be sent to  If you wish to participate, dial: 1-800-837-1935 and Reference Conference ID: 21834666. An audio recording and transcript of this Special Open Door Forum will be posted to the Special Open Door Forum website at and will be accessible for downloading on or around December 9, 2011 and will be available for 30 days. Please see the Downloads section at the following URL for the full participation announcement:

If you need additional information on how these measures will impact your organization- contact BRB Consulting.  We are here for you.


If you are reading this post, then you probably understand the value of rehab….unfortunately- not  everyone does and sometimes, even our legislators don't either.

The recent Obama deficit reduction proposal poses to  disproportionately cut inpatient rehabilitation hospitals and units (IRH/Us) in order to save dollars.  Of $320 billion President Obama has proposed for Medicare and Medicaid savings, $42 billion would come from post acute care providers.   The current  deficit reduction proposal would decrease market basket updates by 1.1% for IRFs in FYs 2014-2021; implement site neutral payments for three conditions plus those which the Secretary may designate; and reinstate of the 75% Rule compliance threshold.   Clearly -these changes would severely compromise IRF's ability to deliver care to many who need it!

So, what can you do?

If you are a Rehab provider , please  reach out to your legislators and members of the Super Committee to oppose these reductions.

If you are a recipient of rehab care-  tell the legislators your story…protect the funds to allow IRF to deliver that rehab care today and tomorrow.

Not sure who represents you…Click on either  the Senate or the House and find out and email or call today.

Legislators need to hear all the stories  about  rehabilitation and the impact  these services have on the lives of their constituents.

Take time now to share the benefits of  REHAB…If you need  more detailed information related to this,   BRB Consulting suggests contacting AMRPA!


BRB Consulting is pleased to share information about our team.  Check out  our professional staff and let us share our expertise with you!

We look forward to exploring together how BRB Consulting  can support your organization.

With experience in a variety of areas including Outcomes Management, Behavioral Health, Nursing or Stress Management, including CARF preparation,  contact us today and   arrange a free telephone consultation!


So the process has begun and the team is ready to tackle an issue.  With the problem identified, now creating solutions can begin.

After finding that one  thing, even if it is  small,  to change;  let the group brainstorm and discover 2 or  3 ways it could look different.  Using the team to develop the tactics to address the problem allows  broad perspectives and can help find novel ways to approach a common issue. The team should pick a combined and agreed upon approach,  and  get everyone on board to fix the issue.   Next establish the  plan of action and the time table to make at least one of the steps for change.

Don’t forget to  select your change agent,  pick someone who  is committed to making this happen.  In many ways, they  are  the champion and can help cheer folks on!

Then as the Nike ads say…Just Do IT!

Do the thing to make the change! Once that  process  is underway, the actions need to be reviewed. Yes, it is very  important to step  back and look at what is happening.

Many organizations use  PDCA– Plan, Do, Check,  Act, which is a simplified pathway to  make sure that the changes made lead to the results desired.

The team should evaluate  to see if the change worked,  if it did- then offer everyone a hearty congratulations! And maybe keep working  to make that process even  better.  But,  if  the change  didn’t work to get the desired results… well then – it’s back to the drawing board and  PDCA starts all over again.

BRB Consulting hopes these  ideas can help your team manage change as a natural part of  the cycle of  work.  As each team member gains understanding and begins to incorporate the process knowledge from each project,  change just  might get a little easier.

If  you’re  still not sure  on how to get started on a change  or if your plans are not working-       BRB Consulting is here to help.  Contact us today and let us be your change agent.

We look forward to hearing from you soon!


As the weather begins its transition into fall,  and the leaves begin to turn  colors,  it is a perfect time to think about change on a larger scale.  Many of us reflect from time to time on what we or our organizations could do better or even about things we  wish we could stop doing altogether.

So where to begin? Start with  something that matters, a facility problem, an employee issue or maybe a challenge for patients/clients.  Once  you decide what it is you want to tackle,  gather a team to help; successful change  requires analysis  and planning;  for that  two,  or even more heads are definitely better than one.

Next try  a brainstorming session to first define the issue,  then let loose  creative ideas on what might be a fix.  (Do have someone take notes!)  Then begin analyzing and weighing the team’s thoughts,  it is okay to take time.  Give  your group permission to “reflect” on the concepts that have been shared.

After thoughtful consideration, the team’s imperative is  to select the best approach to address the change desired.  Now the work should  focus on creating the actions for making something different happen.

As the team defines these procedures, establish just  one  goal for one small change.  Although  it may not seem like much, targeting that will lead the team to achieving the larger goal.

“Rome was not built in a day”  may become a mantra for the team. Working together, know the change can happen -there’s proof – Rome still exists  today!

With those beginning steps, you are ready to become a change agent. Join us again in two week for the next installment of A Season for  Change.

To learn more now or want some help in starting change in your program- contact BRB Consulting today.


BRB Consulting is committed to making today’s healthcare environment a better place for providers and consumers.  During the past year, Bonnie Breit, working with Tom Moore, developer of Midg-ett Tables™   launched EZ-Rest Retractable Folding Chair® as a solution for persons needing a quick rest in hallways or while waiting in areas of refuge.

Following  a comprehensive  accessibility review,  Kingston General Hospital (KGH) located in  Kingston, Ontario recognized an unmet need from their   patients who regularly expressed concern of needing a place to rest while traveling  KGH’s many long hallways.

So,  KGH bought and installed EZ-Rest®. Visitors can stop, sit  and take a quick rest on the new “Rest Station”.  Now everyone at KGH is  discovering the benefits of EZ-Rest® directly.

We invite you to read  their story to see the how adding EZ-Rest® in your building can improve not only access, but consumer satisfaction as well.

Feel free to contact us for more information and see how EZ-Rest® is improving access…one chair at a time.