Payment Matters: Rehabilitation Agencies – Service Expansion No Longer Limited by Tier 4 Survey Status

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Rehabilitation agencies are no longer limited by CMS’ low survey priority — option available to begin operations or expand into new jurisdictions. In an April 22, 2011 final notice, CMS announced its approval of the American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF), commonly referred to as the QuadASF, to perform deemed status accreditation surveys for “organizations that provide outpatient physical therapy and speech-language pathology services” in accordance with the regulations in 42 C.F.R. part 485. These are the regulations applicable to rehabilitation agencies.

In a November 5, 2007 Survey and Certification Letter [PDF], CMS included Medicare-certified rehabilitation agencies among the lowest level, or Tier 4, priority for being surveyed, which significantly affected the ability to begin operations or expand into new geographic areas. In response to the S&C Letter, many states either did not perform any Tier 4 surveys or the wait list was so long that there was limited possibility that a survey would be conducted. Providers now have the option to obtain a new enrollment by seeking approval via a deemed status accreditation survey. Information on the accreditation process is available on the AAAASF website.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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