06/03/13 Inpatient Rehabilitation Facility (IRF ... - WPS Medicare

Monday Mornings with Medicare: Inpatient Rehabilitation Facility Therapy Documentation Teleconference June 3, 2013 K. Cheyenne Santiago, RN Senior Nurse AnalystBackgroundThe fiscal year 2010 Final Rule for the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS)(CMS 1538-F) (http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/Listof-IRF-Federal-Regulations-Items/CMS1227452.html)implemented new IRF coverage requirements. Thesechanges were effective for all Medicare IRF discharges occurring on or after January 1, 2010. The new IRFcoverage requirements replace coverage criteria that were over 25 years old.AgendaRole of documentationDocumenting therapy servicesUse of group/concurrent therapyIntensity exceptionsCommon findingsPurpose of DocumentationImportance of Documentation○ Record of all care a beneficiary receives and the reasons for that care○ Link between delivery of care and payment○ Supports need for and delivery of intense rehabilitationIRF BenefitThe inpatient rehabilitation facility benefit is designed to provide intensive rehabilitation therapy in a resourceintensive inpatient hospital environment for patients who, due to the complexity of their nursing, medicalmanagement, and rehabilitation needs, require and can reasonably be expected to benefit from an inpatientstay and an interdisciplinary team approach to the delivery of rehabilitation care.Medicare contractors must consider the documentation contained in a patient’s IRF medical record whendetermining whether an IRF admission was reasonable and necessary.IRF DocumentationRequired documentation during admission process○ Preadmission screening○ Post-admission physician evaluation○ Overall plan of care○ Admission ordersCreated 02/19/13 1http://www.wpsmedicare.com/

○ IRF-PAIDocumentation during IRF stay○ Physician visits http://www.wpsmedicare.com○ Interdisciplinary team conferences○ Therapy services○ Nursing care○ Ancillary servicesTherapy ServicesCoverage requirements○ Multiple therapy disciplines• Physical therapy• Occupational therapy• Speech-language pathology• Orthotics/prosthetics• One therapy must be PT or OT○ Intensity of services• Patient requires intensity on admission• 3 hours per day / 5 days per week• 15 hours a week - 7 consecutive day period starting with day of admission ○ Required therapy treatments initiated within 36 hours• From midnight of admission date• Therapy evaluation may constitute initiation of therapyKey elements of documentation○ Components of documentation• Initial therapy evaluation• Therapy reassessments or re-evaluation• Therapy progress notes○ Supporting intensive therapy services• Include actual time○ Ability to Actively Participate• Patient able to actively participate in & benefit from IRF care- Upon admission○ Measurable Improvement• Expected to be accomplished within predetermined reasonable period of time• Goal: - Safe return to home or community-based environment - Complete independence not required • Medical record shows functional improvements are: - Ongoing and sustainable - Of practical value- Measured against patient’s condition at start of treatment2

Use of group/concurrent therapy○ Standard of IRF care is individualized therapy○ Group therapies serve http://www.wpsmedicare.comas adjunct to individual therapy• Justification for group therapy documented in medical recordIntensity exceptions○ Brief exceptions may be granted• Not to exceed 3 consecutive days• Cannot be granted in the first three days of the stayCommon FindingsPatient did not required the intensive rehabilitation therapy services that are uniquely provided in anIRF, upon admissionPatient required multiple therapy disciplines (one of which must be physical therapy or occupationaltherapy), upon admissionPatient not able to actively participate, upon admissionSignificant practical improvement was not expectedTherapy services not initiated within 36 hours of midnightAcronymsIRF - Inpatient Rehabilitation FacilityIRF-PAI - Inpatient Rehabilitation Facility Patient Assessment InstrumentOT - Occupational TherapyPT - Physical TherapySLP - Speech Language PathologyWPS - Wisconsin Physicians ServiceReferencesCMS Internet Only Manuals (IOMs)○ 100-02 Medicare Benefit Policy Manual• Chapter 1, Section 110 (http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c01.pdf) ○ 100-08 Medicare Program Integrity Manual• Chapter 3, Sections 3.3.2 - 3.3.2.5 (http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c03.pdf) Medicare website○ http://www.cms.gov/○ Coverage Requirements• http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/Coverage.html3