If you haven’t visited the RAC websites to review the approved IRF audit items for your area, it’s time to start. I also recommend revisiting my blog about contractor entities for useful links and updates. The items approved for audit are directly related to published guidelines and conditions of participation as well as conditions or basis for payment allowance. When the 2010 regulations were published in August of 2009, there were additional areas added to the Basis of Payment section at 412.622. Prior to that time, this section ended at 412.622 (2). Upon finalization of the rule in 2010, sections (3) – (5) were added to the government printing office CFR under 412.622 – Basis of Payment .
These CFR sections specifically detail the requirements for coverage and section (4) of the law specifically highlights the documentation requirements specific to payment allowance. If you print this section and create a checklist from the requirements, it will be very difficult to fail an audit.
In fact, I recommend that a rebuttal form specific to these areas is crafted so that these sections of a chart can be tagged in defense during chart review. By using the exact sections of law and demonstrating that the information is in fact in the medical record, it would be impossible to argue that the Basis of Payment is not covered specifically.
If you find upon audit that these areas are in question, it provides your facility with very specific performance improvement as an action plan toward compliance in meeting the detailed regulations.