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Written by: Darlene D'Altorio-Jones (1959-2015) on Tuesday, November 1, 2011 Posted in: Inpatient Rehab

Sometimes I am ribbed just a bit for reading regulations during the weekend rather than picking up some other literature to absorb my spare time; I think about it and just smile. For those of you who know me personally, entertainment comes in many varieties and I often find reading regulations entertaining; to me there is a great puzzle and finding the pieces that align and don’t make it challenging and rewarding. I learn quite a bit while reading regulations and I feel the time spent can make ‘work life’ and my ability to help others in these hectic times a lot simpler. So for your enlightenment, I’ll keep reading and sharing a few tidbits here an there!

Take for instance what I read this past weekend while thumbing through the final 2012 SNF Regulations; 1351F.

About 14 pages into the 77 page document, I had seen that the government was providing empirical evidence for a statement made by someone when the proposed rule was published. The individual apparently commented that it was better to serve hip fracture patients at a skilled level of care because it saved the Medicare Trust Fund money. CMS responded:

“Finally, as one commenter highlighted, shifting IRF patients toward SNF care does not necessarily improve the quality of care provided to the beneficiaries. A March 2005 report in the Archives of Physical Medicine and Rehabilitation (available at http://
) found that 81.1 percent of IRF patients were discharged to home, compared to 45.5 percent of SNF residents. Additionally, IRF patients appeared to have shorter lengths of stay, averaging approximately
a 13-day stay, compared to the average 36-day stay for a SNF resident. Finally, when patients discharged from each setting were reviewed 24 weeks after discharge, IRF patients had consistently better outcomes and displayed a faster rate of recovery. Given these findings,
we do not agree with those commenters who would assume that shifting patients from the IRF setting to a SNF setting is necessarily more beneficial to the patient or the Medicare Trust Fund. We do, however, intend to conduct additional research to update these findings with more recent data.”

To this I comment. The purpose of the pre-admission screen for inpatient rehab is to defend a level of care that meets each of the 2010 IRF coverage criteria. If you see a patient that meets those criteria and clearly has the ability to return quickly to the community given intense, multidisciplinary level of care while keeping risks at bay, defend an IRF level of care. If you feel the patient is not at great risk and will do well with perhaps just a little less intense rehabilitation and does not require continued education or training that would be provided with higher rehabilitation nursing contact time then skilled should be recommended. Nursing care coverage is defined for your area locality at the SNF Compare CMS website.

Our professional obligation is to do the right thing for each patient and to utilize their benefits in the most cost economical fashion. Value will continue to be defined as post acute care struggles to better align care levels to patients specific needs. Knowing the guidelines and using this type of information makes that job just a little easier. So for that…I’ll keep reading the regulations. I am quite happy carrying my tablet and linking in when the moment allows it.

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