If you casually believed that the IRF 2010 Regulations were guidelines and not mandates, you may be placing yourself in harms way. Auditing records consistently, demanding appropriate workflow completion and providing reports and documentation to meet the criteria for your Medicare Part A patients and all others that under contract require you to follow these guidelines are important. There are very few facilities that have money in reserve to manage the findings discussed in this OIG Report.
Extrapolation of damages back to 2010 could be devastating to providers. If in preponderance you are not following the regulations for your Medicare population, you too could be at risk. If your physicians believe that timeliness of published guidelines are not really meant to be ‘specific’ but just guidelines; there is nothing further from the truth. The 2010 regulations provide no less than 47 items that need monitored for completion. Not just in the first 4 days of the stay but throughout the entire stay. Not having a hardwired workflow to ensure success in meeting these requirements in preponderance for your population is fool-hardy to say the least.
Use this free IRF Clarifications Tool to be sure you are interpreting guidelines as CMS intends you to apply the regulations. There is a ‘keyword’ look up, or you can select a specific regulation category and that will take you directly to the source document at CMS.
If you don’t already have a checklist available to help with an audit, I can provide a template. Email me at firstname.lastname@example.org and I can share one with you and recommendations for use. In addition, I have created two different rebuttal templates that specifically follow the 2010 mandates. If you use exact federal register requirements when responding to an additional development request (ADR) you will be certain to find, tag and provide all the necessary documentation to demonstrate compliance as instructed.
Let’s pause for one moment and put the title of your own facility in the headlines of that OIG article. It’s very possible that documentation was available but it was unclear, poorly labeled or not in the correct place of the medical record. The regulations presently have 155 specific clarifications to interpret process appropriately. Clarity of interpretation and follow through is paramount. To correlate with the published article, what if any of these scenarios were true? Think about your own process and see if any of these possibilities or others exist…
(1) Documentation that a comprehensive preadmission screening occurred within the 48 hours immediately preceding the admission:
- Because this process is done while the patient is in the acute care side of the facility, the medical record department scanned the documentation to the acute care and not the rehabilitation medical record.
- The persons that registers patients placed approximate times of admission onto the chart for arrival and not the ‘real’ time; not aware of the very important 48 hour window.
(2) Documentation that a rehabilitation physician performed a postadmission evaluation within the first 24 hours of the IRF admission,
- The post admission evaluation and the history and physical are one and the same, however it does not clearly label and or not every question required in the post admission evaluation was evident.
- How many facilities within the post admission evaluation attest within the document; ’I, the rehab physician…?’
(3) Documentation that a rehabilitation physician developed and documented an individualized overall plan of care within 4 days of the IRF admission,
- Each facility may develop their own procedures to meet this requirement. Are all the elements required answered within the plan of care and is it evident that the physician’s input and final approval to the plan were sealed by the end of the 4th day?
- Some facilities meet the H&P, Post Admission Evaluation and the Plan of Care in the same note. Although not recommended by clarification it is allowable. Imagine how confusing an audit is to align exact elements when these are a merged document.
(4) documentation that interdisciplinary team meetings met all federal requirements. The hospital’s procedures did not ensure that IRF services were documented according to Medicare requirements.
- There are 16 clarifications for interdisciplinary team conference. Often these conferences are a round table of staff reiterating progress notes as present status and NOT meeting the defined four bulleted purpose of team conference.
As a company we can provide you with the very best tools to help monitor these mandates in advance of them being missed or forgotten. We are here to improve your success and reduce your risk as an IRF attempting to stay on top of this very issue; we have solutions that make monitoring required elements simple. Come browse our website!