AOTA Weighs in on Medicare IRF Classification Criteria
AOTA had a seat at the table during the Centers for Medicare & Medicaid Services (CMS) Inpatient Rehabilitation Facility (IRF), Technical Expert Panel meeting at CMS headquarters. AOTA was well represented by member Janet Raisor, OTR/L, during the discussions. CMS has initiated a study into the practicality and usefulness of the classification criteria applicable to IRFs commonly known as the “75 percent rule,” which bases designation of a facility as an IRF only if 75% of its patients are admitted with one of 13 conditions.
AOTA has significant concerns regarding the 75% rule (which is currently the 60% rule). Occupational therapists and occupational therapy assistants provide key intensive rehabilitation services in IRFs. Consequently, occupational therapy practitioners are well aware that the 75% rule fails to accurately reflect the increasing need for patients with diagnoses outside of the existing 13 conditions to have access to inpatient rehabilitation hospital care. AOTA supports a classification system that considers the whole patient in terms of functional status and need for intensive rehabilitation services.
AOTA had the opportunity to provide an official comment letter pursuant to the February 2, 2009, CMS Town Hall Meeting to gather public input about the IRF classification criteria. AOTA believes that these comments will assist CMS’s contractor, RTI International (RTI), in its study of these issues and inform CMS in preparing a Report to Congress required by the Medicare, Medicaid and SCHIP Extension Act of 2007, due in June. After submitting its Report to Congress, RTI is tasked with conducting research and gathering data that will help inform potential recommendations for a modified IRF classification system.
AOTA will continue to monitor the Medicare IRF study and post updates as new developments arise.
The 60 percent rule, formerly known as the 75 percent rule, is a criterion used to define inpatient rehabilitation facilities in order for them to receive payment as an IRF. The 60 percent rule was effective July 1, 2007. More information on IRFs and the 60 percent rule is available in an October 2008 MedPAC IRF Payment Basics Report.