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.
The term “stopgap” is defined as “a temporary way of dealing with a problem, and something used as an emergency measure until something better can
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