Ultimately, we are expected to do what is best for the patient’s plan of care. If by adding time in the patient’s “rolling seven calendar day” week is stressful, or not in the best interest of the patient, that would be stated as part of the documentation. Once documented, this missed time would count toward the brief exception allowance that CMS has defined not to exceed three consecutive days. If three hours cannot be tolerated beyond three days, it would denote that the patient is unable to continue therapy at an intensity level required to sustain an IRF level of care and initiate discussions to begin discharge planning. If a physician felt the “crisis” was remedied and in good faith rehab could resume per original plan, continuing rehabilitation at the IRF would be supported. If a patient had continuous three day breaks, intensity of rehabilitation could be challenged and the value of an IRF level of care could be challenged.
Therefore, if it’s not in the best interest of the patient to make up time, the exception policy should be followed and the circumstances documented. If it’s felt that the patient can tolerate added time and it would be beneficial, it should be added to the patient’s schedule as time added that would be considered towards meeting 15 hours over seven days with appropriate documentation.
See clarification documents at the CMS IRF webpage concerning this discussion.
Version 3, page 3 and Version 4 page 12.
Mediware recently hosted a community webinar that spotlighted Burke Rehabilitation’s change from decentralized to centralized scheduling and how it helped them manage compliance to the 3 Hour Rule.