In an effort to meet 2010 criteria, IRFs have had to add much more auditing and screening to their daily practices. Many of the rules are definitive with specific time frames, types of information and deadlines to be performed. Facilities must audit and correct variances whenever noted so that practice is guided toward full compliance. Recently, I was asked this question:
Do evaluations go toward the 3 Hour Rule? Three hour rule is also known as meeting rehabilitation “intensity”. The answer to that question can be found in the following areas of the clarification documents at the CMS IRF webpage:
Version 2 – page 3, question 3, and Version 4 – page 10, question 37 both detail that the evaluation is counted toward the 3 Hour Rule (intensity toward therapy.) Version 4 even defines further clarification around that statement.
Version 3 – page 4, question 15 – Stating when the evaluation can begin and answers the question if only one evaluation can be started within 36 hours.
Version 4 – page 1, question 5 – Clarifies that if by state practice assistants can contribute to the therapy evaluation is that permitted for CMS.
Version 4 – page 4, question 17 – Can evaluations begin prior to the physicians Post Admission Evaluation.
Given these examples, it is clear that yes, evaluations are included in the 3 Hour Rule and do demonstrate the intensity of therapy toward counting 3 hours on the day evaluations are completed.
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.