While supplies last! Free 2022 Coding Essentials for Infusion & Injection Therapy Services book with every RACmonitor webcast order. No code required. Order now >

Inpatient rehabilitation facilities (IRFs) will continue to face a plethora of audits from a variety of regulatory agencies during 2016. Each of these agencies has a work plan or scope of work to be accomplished during the year. So there’s no time like today for IRFs to establish their own “work plan” for preparing for audits and reducing the risk of claim denials.

In establishing this work plan, IRFs should consider the following topics. 

Assess Your Vulnerabilities

The majority of our client IRFs have ongoing audit programs to identify documentation concerns related to the support of reasonable and necessary IRF care. Review your audit programs to be certain you are assessing the same elements as the Medicare Administrative Contractors (MACs) and Recovery Auditors (RAs) when determining whether it is “reasonable and necessary” for care to be provided in the IRF. Determine where you have the greatest exposure on an external audit.


Look for areas of significant risk and address those first. If you have a high level of float staff, perhaps you can establish just-in-time training and review programs to be sure that their documentation is both timely and complete. Conversely, if your core staff has become desensitized to the need for timely and accurate documentation, now might be an excellent time to do some training. 

It’s likely that most IRFs have already identified key areas for improvement. Focusing on the higher-risk, higher-volume error rates will provide the best return on investment of employee time and resources.

Update Your Regulatory Library

IRF regulations and clarifications from Medicare change frequently. Be certain that you are working from the most recent versions of the IRF regulations, including the Medicare Claims Processing Manual, the Medicare Benefit Policy Manual, the IRF-PAI manual and the associated documents in the Federal Register. 

Take a Look Back to Oct. 1, 2015

It’s now more than 90 days since the requirements for reporting modes and minutes of therapy and the arthritis attestation became effective. Perform an internal audit to determine how well your organization is doing in meeting the requirements of these new fields on the IRF-PAI.

For modes and minutes of therapy: Does the data you are reporting demonstrate that your patients are meeting the intensity-of-therapy requirements? If not, have you verified that the record clearly reflects the reasons for missed therapy and the response of your team to address those issues? 

For the arthritis attestation: When required, does the record include documentation to support arthritis as a qualifying condition? And does the IRF record also demonstrate that the rehab program addressed the arthritis condition during the course of care? If not, you may have some work to do. 

Get to Know Your RA and Your MAC

As the Recovery Auditor program moves back into full swing, it is essential that IRFs monitor the activities of their assigned RA. Contractors typically post their issues, currently under both automated and complex review. Additional information related to the RA process is also available.

Each RA also typically posts the regulatory policy links that are related to the RA issue so that the provider can easily access the documents related to the specific issue being reviewed.

Links to each of the RA websites are provided in the table below.



Region A:

Performant Recovery

States: CT, DE, DC, ME, MD, MA, NH, NJ, NY, PA, RI, and VT.



Region B:


States: IL, IN, KY, MI, MN, OH, and WI.


Region C:

Coviti (Formerly Connolly)

States: AL, AR, CO, FL, GA, LA, MS, NM, NC, OK, SC, TN, TX, VA, WV, Puerto Rico, and the U.S. Virgin Islands.




Region D:


States: AK, AZ, CA, HI, ID, IA, KS, MO, MT, ND, NE, NV, OR, SD, UT, WA, WY, Guam, American Samoa, and Northern Marianas.



Each MAC also provides a significant amount of information on its website. The information tends to be much more extensive than what is provided on the RA websites. MACs typically post not only the issues under review, but the results of audits as well as educational materials to assist providers in improving performance.  

Information related to current and past MAC audits is located under the Medical Review tab of the MAC website. 

Focus on Quality Indicators

Review your processes for collecting quality indicator information and verify that you are reporting the required information in a timely fashion. Information reported today will impact future payments, and meeting the time and data requirements is essential to achieving future financial health. 

Additionally, because these indicators eventually will impact payment for services, either through bonuses or penalties, IRFs should be evaluating their performance in these areas and establishing plans for improvement in areas where they identify opportunities.

Get Ready for IMPACT

Effective Oct. 1, 2016, IRFs will begin using Version 1.4 of the IRF-PAI document, which expands the data collection requirements to a robust 18 pages of information that will be reported for each Medicare or Medicare Managed Care patient. The Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 mandated that all post-acute settings collect quality data and that that data be standardized for functional status, cognitive, function, and medical needs. This means that home health, skilled nursing facilities, inpatient rehabilitation facilities, and long-term acute-care hospitals will be collecting this data with standardized assessment data collection beginning in 2018. 

Because of the additional data collection requirements for IRFs beginning this October, IRFs should start now to update any medical records, forms, or templates to establish processes that define who will collect the data and begin training on the appropriate way to complete the assessment(s). 

The Bottom Line

While we have yet to hear of extensive new audits being initiated this quarter, there continue to be many areas for IRFs to focus on improvement.  A solid, written work plan with goals, assigned responsibilities, and timelines for achievement can set the stage for success in 2016.

About the Author

Angela M. Phillips, PT, is president  and chief executive officer of Images & Associates. A graduate of the University of Pennsylvania’s School of Allied Health Professions, she has almost 40 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting inpatient rehabilitation facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

Contact the Author


Comment on this Article



Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

You May Also Like

Leave a Reply

Your Name(Required)
Your Email(Required)