Somehow 2012 went by quickly and the last we updated the CMS Clarifications on IRF Regulations tool it was mid-July. Since that time there has been several clarifications posted to the CMS website providing further discussion and interpretation from various training calls and submissions to their IRF specialists. Below are three links to those very specific documents; however if you want to find them through a keyword or a specific top we have added these directly to our look up tool. It brings the total clarifications for IRF Coverage Criteria to 155 published discussions.
These clarifications define appropriate interpretation and expectations for the 14 coverage criteria specific to the 2010 Rules. I’ve included an updated graph showing the number of discussions on each topic. It is recommended that each facility review these criteria and set dashboards toward meeting the various expectations. Seeing that many areas can lead to non-payment, it is never too late to adopt best practices in meeting the intent of interpretation. Recall that if ‘in preponderance’ your workflows do not support these very specific rules, it is not unheard of for fiscal intermediaries and RAC auditors to issue denials for non-payment and then pull additional charts to detect patterns of bad practice. Your hard work and even successful outcomes can be thrown away as a hit/miss in reimbursement just because standards for 412.622 – Basis of Payment are not evident in documentation.