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The U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) released its 2017 work plan, which includes a list of reports it plans to publish during the year. Included in the plan are several items related to inpatient rehabilitation facilities (IRFs), including: 

  • New work:
    • A case review of IRF patients who might not be suited for intensive therapy.
  • Revised work:
    • A review of whether IRF billed claims are in compliance with Medicare documentation and coverage requirements.

What’s New?

While it appears that the identification of the issue regarding IRF patients who might not be suited for intensive therapy occurred during earlier work by the OIG, specifically related to adverse events in IRFs, this matter is certainly not new to us, based on our work with compliance audits. 

The January 2010 clarification documents for IRFs included detailed information related to the provision of intensive therapy services.  While the generally accepted standard for demonstration of the intensity of therapy services is the necessity of providing them at least three hours per day, at least five times per week, Medicare agrees that this is not the only way of illustrating that such services are required. In some cases, the required intensity could be demonstrated by providing 15 hours of therapy over a seven-day week. Additionally, there is a “brief exceptions policy” that addresses missed therapy minutes due to unexpected clinical events. 

What’s Being Continued or Revised?

The 2016 work on Inpatient Rehabilitation Facility Payment System Requirements (W-00-17-35791) is now expected to be completed in 2017. This area of work will determine whether IRFs nationwide billed claims in compliance with Medicare documentation and coverage requirements. The work appears to be focused on the IRFs meeting the clarified requirements in the January 2010 regulatory documents, including the time and content of the following documentation:

  • Preadmission assessment screening;
  • Post-admission physician evaluation;
  • Individualized plan of care; and
  • Team meetings, along with all of the documentation to support the required intensity of therapy. 

The Bottom Line

There continues to be a great deal of scrutiny on IRF claims related to the technical requirements that were clarified almost seven years ago, and organizations have not fared well under that scrutiny. 

The audits simply are not going away! 



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.

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