On March 13, the Centers for Medicare & Medicaid Services (CMS) issued blanket waivers that will impact Inpatient Rehabilitation Facilities (IRFs) as well as other Post-Acute Care (PAC) settings. The blanket waivers, which do not require any special request to be filed, will allow IRFs to admit patients to IRF beds for emergency treatment of COVID-19, and to exclude these patients from the CMS 60-percent calculations. IRF patients may also be housed in other acute beds within the facility, if needed, to provide the appropriate response to increasing numbers of COVID-19 cases.
Overview
Medicare’s Emergency Declaration Fact Sheet, located on the CMS website at https://www.cms.gov/files/document/covid19-emergency-declaration-health-care-providers-fact-sheet.pdf provides details for all post-acute settings. Specifically:
What This Means for IRFs
Flexibility in Patient Bed Assignment
When an organization has a requirement for beds that can be met by placing an acute patient in an IRF bed, the organization may proceed accordingly, provided that the case is clearly documented in the medical record. Conversely, if IRF beds are more appropriate for care of acutely ill patients, the IRF beds may be used for that purpose, and IRF patients may be treated in acute beds.
Billing Issues
These waivers provide organizations with flexibility in moving patients to and from open beds in order to ensure that needed care is provided. IRFs may house patients receiving acute care if appropriately designated in the medical record. CMS has posted additional policies and procedures related to this here:
https://www.cms.gov/About-CMS/Agency-Information/Emergency/Downloads/MedicareFFS-EmergencyQsAs1135Waiver.pdf.
As noted on page 31 of this document, IRFs should use condition code DR to note that the entire stay is disaster/emergency-related. This applies only to patients who are admitted to the IRF for non-IRF services.
Payment Issues
CMS has not indicated how claims admitted under the waivers will be paid, but historically, it has been under the IPPS payment systems.
Beware: IRF Requirements Still Apply
For admissions for IRF services that are not related to the disaster, the IRF must continue to meet all relevant requirements.
EDITOR’S NOTE Day 3 of the federal shutdown continues. This article by Mark Spivey is part of a special section today published by RACmonitor and
As expected, the federal shutdown began early Wednesday morning. What’s unknown is how long it will continue. Neither congressional Republicans nor Democrats appear to be
Please log in to your account to comment on this article.
Accurately determining the principal diagnosis is critical for compliant billing, appropriate reimbursement, and valid quality reporting — yet it remains one of the most subjective and error-prone areas in inpatient coding. In this expert-led session, Cheryl Ericson, RN, MS, CCDS, CDIP, demystifies the complexities of principal diagnosis assignment, bridging the gap between coding rules and clinical reality. Learn how to strengthen your organization’s coding accuracy, reduce denials, and ensure your documentation supports true medical necessity.
Denials continue to delay reimbursement, increase administrative burden, and threaten financial stability across healthcare organizations. This essential webcast tackles the root causes—rising payer scrutiny, fragmented workflows, inconsistent documentation, and underused analytics—and offers proven, data-driven strategies to prevent and overturn denials. Attendees will gain practical tools to strengthen documentation and coding accuracy, engage clinicians effectively, and leverage predictive analytics and AI to identify risks before they impact revenue. Through real-world case examples and actionable guidance, this session empowers coding, CDI, and revenue cycle professionals to shift from reactive appeals to proactive denial prevention and revenue protection.
Sepsis remains one of the most frequently denied and contested diagnoses, creating costly revenue loss and compliance risks. In this webcast, Angela Comfort, DBA, MBA, RHIA, CDIP, CCS, CCS-P, provides practical, real-world strategies to align documentation with coding guidelines, reconcile Sepsis-2 and Sepsis-3 definitions, and apply compliant queries. You’ll learn how to identify and address documentation gaps, strengthen provider engagement, and defend diagnoses against payer scrutiny—equipping you to protect reimbursement, improve SOI/ROM capture, and reduce audit vulnerability in this high-risk area.
Only ICD10monitor delivers what you need: updates on must-know changes associated with the FY26 IPPS, including new ICD-10-CM/PCS codes, CCs/MCCs, and MS-DRGs, plus insights, analysis and answers to your questions from two of the country’s most respected subject matter experts.
Get clear, practical answers to Medicare’s most confusing regulations. Join Dr. Ronald Hirsch as he breaks down real-world compliance challenges and shares guidance your team can apply right away.
Federal auditors are zeroing in on Inpatient Rehabilitation Facility (IRF) and hospital rehab unit services, with OIG and CERT audits leading to millions in penalties—often due to documentation and administrative errors, not quality of care. Join compliance expert Michael Calahan, PA, MBA, to learn the five clinical “pillars” of IRF-PPS admissions, key documentation requirements, and real-life case lessons to help protect your revenue.
During this essential RACmonitor webcast Michael Calahan, PA, MBA Certified Compliance Officer, will clarify the rules, dispel common misconceptions, and equip you with practical strategies to code, document, and bill high-risk split/shared, incident-to & critical care E/M services with confidence. Don’t let audit risks or revenue losses catch your organization off guard — learn exactly what federal auditors are looking for and how to ensure your documentation and reporting stand up to scrutiny.
Learn how to navigate the proposed elimination of the Inpatient-Only list. Gain strategies to assess admission status, avoid denials, protect compliance, and address impacts across Medicare and non-Medicare payors. Essential insights for hospitals.
Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
