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Written by: Mediware on Monday, September 3, 2012 Posted in: Inpatient Rehab

There’s an unwritten “belief” that just because a rehabilitation level of care is considered an acute hospital stay, it’s completely OK to save coding the IRF PAI for discharge.  If you  operate in one of those facilities and you’ve been struggling for years to educate that your tool must be “completed” at the front and back ends, but have received push back from your coding department because that takes “too much” time to do it once and then do it again, then this blog is for you!

How do we know coding must be completed in the IRF PAI during the admission assessment reference dates (ARD)? If you’re paid under the IRF PPS, you’re considered an excluded unit and the conditions of participation as a fee for service Medicare Part A (IRF/U) provider are unique and special.  You must follow the coverage criteria and conditions of participation to be paid.  If you’re speaking on deaf ears, because after all, you’re just a few beds in a monstrous facility you couldn’t possibly know what you’re talking about, here are the areas you need to reference so that you can pull yourself into compliance.

Admission assessments are not an option, they are required for all part A and part C Medicare beneficiaries. These conditions of participation are covered in  Title 42 Volume 2, Chapter IV, Section 412 Subpart P; Prospective Payment for Rehabilitation Hospitals and Units. This section covers the payment and assessment requirements for rehabilitation patients.

Who wants to argue?  Not only is it regulatory, the co-morbid conditions coded on the IRF PAI are the conditions that make the stay “reasonable and necessary” to manage a patient at a rehabilitation level of intensity.  You are required to “complete” all sections of the IRF PAI on admission by day four, unless it’s labeled as a “discharge”  area.

“The federal regulations require that data must be collected and entered into the data collection software (i.e., encoded) by specified time periods. An inpatient rehabilitation facility may change the IRF PAI data at any time before transmitting the data, but only if the data were entered incorrectly,” page II-1  IRF PAI Manual 2012.

Admission co-morbidities determine the tier level portion of the HIPPS payment code. The etiologic diagnosis and impairment group code determine the CMG level of a particular rehabilitation impairment code (RIC).  Data inputs lead to a case mix index amount that identifies resource intensity and payment for the patient conditions you have assessed in total.



It is true that on discharge, you may add to the co-morbid listings all diagnoses that were managed prior to the final two days of the patient’s stay. In addition, you should add complications that expended resources for all care conditions recognized and treated after admission, in addition to those identified in the co-morbidity section item 24 of the IRF PAI that were present on admission.


Initial encoding is the basis for identifying the resources that will be required to care and pay for the stay.  The earlier these are identified, the earlier staff can work in unison to collaborate and care for the listed conditions along with the patients functional rehabilitation; all leading to improving the coordination of effort in achieving discharge barriers and managing the clinical conditions that must be considered to successfully rehabilitate the patient’s recovery.

If you practice the correct way, the patient has the benefit of all staff working as a team to manage these areas and your chart audits will fare better because it will be much more clear that the entire team is working to mitigate risks for these conditions and teach the patient how to manage them more independently for home going, and possibly reducing returns to acute care as well.

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