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Written by: Darlene D'Altorio-Jones (1959-2015) on Wednesday, October 10, 2012 Posted in: Inpatient Rehab

Each year the Office of the Investigator General(OIG) releases their intended work plan.  This plan becomes the road map for their office in determining compliance to expected practices.  It’s a wake up call for all facilities for high priority “sonar” specific to their area of practice.Issues that are often high volume or problem prone, that may need review for appropriate practice to align with legal expectations, are noted in the Work Plan. The OIG intends for you to take note, audit and realign practice accordingly.  Most likely your compliance officer keeps this as their “little black book” of checks and balances from year to year.

OIG states this is what you can learn from the Work Plan.

What can you learn from our Work Plan?
“The OIG Work Plan outlines our current focus areas and states the primary objectives of each project. The word “New” after a project title indicates the project did not appear in the previous Work Plan. At the end of each project description, we provide the internal identification code for the review (if a number has been assigned), the year in which we expect one or more reports to be issued as a result of the review, and whether the work was in progress at the start of the fiscal year or is planned as a new start. Typically, a review designated as “work in progress” will result in reports issued in FY 2013, but a review designated as “new start,” meaning it is slated to begin in FY 2013, could result in a FY 2013 or  2014 report, depending on the time when the assignments are initiated during the year and the complexity and scope of the examinations.”

The three items listed for IRFs in the 2013 plan are the same as last year’s plan.  

  • Late transmission penalty applied by MAC/FI when IRF-PAI submission equaled 27 days or later to CMS
  • Appropriateness of the IRF Admission
  • Utilization of concurrent and group therapy during an IRF stay

The twist?The expected issue and start dates were updated from the 2012 plan to reflect the new postponed dates to each. See the newest OIG Work Plan 2013 pgs. 1-9 for the updated reference and compare to the snapshot from last year’s plan.

Note that “work in progress” items are items that must be reflected in your present workflows to meet those expectations. Future issue dates and start dates are items you need to analyze now to be sure expectations are trending in a positive manner. Appropriateness for the IRF admission are well documented in the 2010 guidelines and clarification documents. CMS had issued clarifications on their expectation toward individualized therapy at an IRF level of care.  Make sure your practices meet expected reviews by proactive analysis and audits.

CMS provided clarifications in regards to group therapy in IRFs:

Clarification regarding the percentage of one-on-one individualized therapy that would constitute the “bulk” of therapy.

A: We expect the preponderance of therapy a patient receives at the IRF to be individualized, one-on-one therapy. IRF patients require an intensive and complex level of therapy services designed specifically to their individual needs. We believe that individualized, one-on-one therapy most appropriately meets the specialized needs of IRF patients. We have not yet established a required percentage of one-on-one individualized therapy in the IRF setting because we are seeking more information on the amount of one-on-one versus group therapies that are most beneficial to patients. The specific benefit to the IRF patient of any group therapy that is provided must be well-documented in the IRF medical record.”

Additional Reference(s): Medicare Benefit Policy Manual 100-02 Chapter 1: Section 110.2.1 & 110.2.2
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