CHA News Article

CMS Clarifies Inpatient Rehabilitation Facility Medical Review, Group Therapy

The Centers for Medicare & Medicaid Services (CMS) has issued the attached MLN Matters article clarifying policies related to the use of group and concurrent therapy in inpatient rehabilitation facilities. The clarification follows extensive communication and advocacy by CHA staff and representatives of CHA member hospitals.   

Over the course of the past year, some CHA member facilities undergoing routine audits by Noridian, the California Medicare administrative contractor, reported payment denials in instances where group and/or concurrent therapy time was included in the three hours per patient day provided to fulfill inpatient rehabilitation facility program requirements, an interpretation of policy that was inconsistent with previous guidance. 

In response, CHA facilitated communication between CMS, Noridian and facilities to express concerns over the change in interpretation and the impact on the affected providers. As a result, CMS agreed to provide the attached clarification, which includes the following statements (emphasis added):    

“This … will require the use of clinical review judgment to determine medical necessity of the intensive rehabilitation therapy program based on the individual facts and circumstances of the case, and not on the basis of any threshold of therapy time.”

“Group and concurrent therapy can be used on a limited basis within the current industry standard of generally 3 hours of therapy per day at least 5 days per week…”  

More information is available in the attached article.