New CMS Rules for Inpatient Rehabilitation

Ruder Ware

Well, it’s a start.  New Medicare rules kicked in starting January 1, 2019 that are aimed at focusing less provider time on paperwork and more on patient care in inpatient rehabilitation facilities.  Any change that reduces paperwork in this overregulated area is welcome, but the actual impact of the announced changes are incremental at best.

In order to be eligible for admission to an inpatient rehabilitation facility (IRF), a patient’s rehabilitation must require physician supervision.  At least three separate face-to-face visits are required every week to meet this requirement on an ongoing basis.  Each visit must be carefully documented in the patient’s record.  In addition to these three visits, a physician is required to conduct a post-admission physician evaluation (PAPE) to document the patient’s status on admission.  The new rules simplify the process by permitting the PAPE to count as one of the three face-to-face visits during the first week of admission.  This at least provides some flexibility for the physician.

Another small but welcome change involves requirements for physician leadership of rehab team meetings.  IRF rules require regular interdisciplinary team meetings to be led by a rehabilitation physician.  It must be clearly documented in the chart that the physician led the meeting.  Physical attendance by the physician at every single meeting often proves challenging.  The new rules permit some flexibility and permit the physician to attend by video or telephone conferencing.  No additional documentation requirements were imposed to reflect the method of communication used by the physician to lead the interdisciplinary team meeting.  It is up to the facility whether to implement process changes that permit remote attendance by the physician.

Any common sense change that cuts down on the regulatory requirements in any element of care is welcome.  But in reality these are very minuscule changes given the numerous regulatory requirements that apply in the rehab service segment.  Hopefully the Centers for Medicare & Medicaid Services (CMS) will dig deeper to continue to implement common sense changes that permit providers to focus more on patient care and less on unnecessary regulatory requirements.

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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