AOTA Needs Feedback on IRF Group Therapy and Other Issues
CMS published a proposed rule in the Federal Register on May 6 that would update payment rates and clarify the framework for Medicare patient selection and care in IRFs during FY 2010. CMS has also posted draft Medicare Benefit Policy Manual revisions for IRFs. In order to be paid for providing rehabilitation services under the IRF prospective payment system, current Medicare law requires an IRF to demonstrate that its annual patient population consists of at least 60% of patients with one or more of 13 “qualifying conditions” as a principal or secondary diagnosis.
CMS is asking for guidance about the types of patients for which group therapy may be appropriate, and the specific amount of group instead of one-on-one therapies that may be beneficial for these types of patients. CMS anticipates using this information to assess the appropriate use of group therapies in IRFs and may create standards for group therapies in IRFs. Because there are currently no rules or guidance in place for the parameters of group therapy in IRFs, we are especially interested in your feedback on this issue.
The proposed revisions would also clarify requirements for preadmission screening to determine whether a patient should receive rehabilitation services in an IRF or in another, less-intensive setting, post admission treatment planning, and ongoing care coordination throughout the inpatient stay.
We are interested in your feedback as to the following CMS proposals:
- Update and clarify the IRF admission criteria to specify that the patient should be able and willing to actively participate in an intensive rehabilitation program and should be expected to make measurable improvement in his or her functional capacity or adaptation to impairments;
- Require that IRF services be ordered by a rehabilitation physician with specialized training and experience in rehabilitation services and be coordinated by an interdisciplinary team, including at least a registered nurse with specialized training or experience in rehabilitation; a social worker or case manager (or both); and a licensed or certified therapist from each therapy discipline involved in treating the patient. The rehabilitation physician would be responsible for making the final decisions regarding the patient’s treatment in the IRF;
- Specify that IRFs use qualified personnel to provide required rehabilitation nursing, physical therapy, occupational therapy, speech-language pathology, social services, psychological services, and prosthetic and orthotic services;
- Emphasize the importance of the post admission evaluation to document the status of the patient after admission to the IRF, compare it to that noted in the preadmission screening documentation, and begin developing an overall plan of care to meet the individual patient’s specific needs. The proposed rule would require the overall plan of care to be completed with input from all of the interdisciplinary team members and to be maintained in the patient’s medical record; and
- Require the interdisciplinary team to meet weekly to review the patient’s progress and make any needed modifications to the individualized overall plan of care.
AOTA has been actively involved in working with CMS on IRF policy changes through participation in a technical advisory panel working group gathered by CMS in February.
Because comments are due to CMS by June 29, AOTA needs to hear from you by June 25th. Please send your comments to firstname.lastname@example.org.
You may access a copy of the proposed rule online at http://www.federalregister.gov/OFRUpload/OFRData/2009-10078_PI.pdf. Click here for the CMS press release. CMS has published Fact Sheets on the IRF rule payment update and coverage requirements. CMS will accept comments on the proposed rule through June 29, 2009.
The draft IRF Medicare Benefit Policy Manual revisions are online at http://www.cms.hhs.gov/InpatientRehabFacPPS/Downloads/Revised_Section_110_MBP_Manual_DRAFT_for_Comment.pdf. Comments on the draft revisions should be submitted through a link that will be supplied on the CMS Web site, rather than through the site used for the submission of comments on proposed regulatory language.