Medicare Releases Policy Guidance for IRFs
On Friday, October 23, the Centers for Medicare & Medicaid Services (CMS) released the anticipated final revisions to the Medicare Benefit Policy Manual (MBPM) Chapter 1, Section 110, which address requirements for medical necessity for inpatient rehabilitation facility (IRF) services. The new provisions are effective for IRF discharges on or after January 1, 2010.
The Manual revisions reflect changes suggested by the American Occupational Therapy Association (AOTA). Among the significant changes are the following items:
- Revised language addressing patient medical status at time of IRF admission
- Addition of pre-admission screening provision, allowing for remote update if admission extends beyond 48 hours
- Extended time frame for documentation of the required interdisciplinary plan of care from the proposed 72 hours to 4 days
- Expanded Medical Necessity criteria, including the addition of sections addressing program requirements for multiple therapy disciplines, patient ability to actively participate in an intensive rehabilitation therapy program, and physician supervision
- New language stating that requirements for personnel qualifications and documentation of therapy services should be consistent across care settings, as described in the MBPM Chapter 15, Sections 220 and 230.
- Require a licensed or certified therapist from each therapy discipline involved in treating the patient to participate in interdisciplinary team conferences at least once per week to make decisions about the patient’s treatment in the IRF, such as discharge planning and the need for any adjustment in goals or in the prescribed treatment program.
Read the MLN Matters Article, Coverage of IRF Services
Read the Manual Changes at Section 110 (CMS Transmittal 119)
Update: After hosting a national conference call on November 12, 2009, CMS posted a series of three follow-up documents to clarify coverage requirements.
Series 1 Follow-up
Series 2 Follow-up
Series 3 Follow-up
Series 4 Follow-up
More information about IRF coverage requirements is available on the CMS Web site.