IRF Group and Concurrent Therapy - JF Part A
IRF Group and Concurrent Therapy
IRF services are covered under the Medicare IRF benefit, when the submitted documentation sufficiently demonstrates that a beneficiary's admission to an IRF was reasonable and necessary, according to Medicare guidelines. Patients who only require treatment by one therapy discipline, do not need to be in an IRF.
Use the links below to jump to information on each topic.
- Initiation of Therapy
- Multiple Therapy Disciplines
- Group and Concurrent Therapy
- Brief Exception Policy
Initiation of Therapy
The required therapy treatments must begin within 36 hours from midnight of the day of admission to the IRF. Therapy evaluations constitute the beginning of the required therapy services. As such, therapy evaluations "count" for the purposes of demonstrating intensity of therapy services in the IRF.
- Example: A patient admitted to the IRF on Friday must start therapy by noon on Sunday
Multiple Therapy Disciplines
At the time of admission to the IRF, the beneficiary must be actively involved in multiple therapy disciplines. Requirements of active and ongoing therapeutic intervention of multiple therapy disciplines include the following, one of which must be physical or occupational therapy.
- Physical therapy (PT)
- Occupational therapy (OT)
- Speech-language pathology
- Require an intensive level of rehabilitation services
Active Participate in Intensive Therapy: Medical Necessity Criteria
- The patient's condition must be such that there is a reasonable expectation at the time of admission that the patient will be able to actively participate in and benefit from the intensive rehabilitation therapy program provided in the IRF.
Essential active participation key elements
- Under current industry standards, this intensive rehabilitation therapy program consists of at least 3 hours of therapy per day or at least 5 days per week. Or in well-documented cases the intensive rehabilitation therapy program might instead consist of at least 15 hours within a 7-consecutive day period, beginning with the date of admission to the IRF.
- Documentation must clearly indicate the clinicians name, professional credentials and the amount (in minutes) of each therapy service provided for each date.
Group and Concurrent Therapy
The standard of care for IRF patients is individualized therapy; one therapist to one patient. Concurrent therapy is one licensed or certified therapist treating two patients at the same time, who are performing different activities.
Group and concurrent therapy can be used on a limited basis within the current industry standard of generally 3 hours of therapy per day at least 5 days per week or at least 15 hours of intensive rehabilitation therapy within a 7-consecutive day period. In those instances, in which group therapy better meets the patient's needs on a limited basis, the situation/rationale that justifies group therapy should be specified in the patient's medical record at the IRF.
Brief Exceptions Policy
While patients requiring an IRF stay are expected to need and receive an intensive rehabilitation therapy program, as described above, this may not be true for a limited number of days during a patient's IRF stay because patients' needs vary over time. If a patient has trouble tolerating three hours a day or has medically necessary tests/treatment, then it would be appropriate to adjust therapy.
During the patient's IRF stay an unexpected clinical event may occur that limits the patient's ability to participate in the intensive therapy program for a brief period not exceeding 3 consecutive days. The specific reasons for the break in the therapy services must be documented in the patient's IRF medical record. When the reasons are appropriate (e.g., extensive diagnostic tests off premises, prolonged intravenous infusion of chemotherapy or blood products, bed rest due to signs of deep vein thrombosis, exhaustion due to recent ambulance transportation, surgical procedure, etc.) are documented such a break in service will not affect the determination of medical necessity of the IRF admission.
- The brief exception policy is not allowed to be used in the first 3 days of the patient's admission
- CMS Internet-Only Manual (IOM), Publication 100-02, Medicare Benefit Policy Manual, Chapter 1, Section 110.2.2, Intensity Level of Rehabilitation
- CMS IOM, Publication 100-08, Medicare Program Integrity Manual, Chapter 6, Section 6.7, Medical Review of Inpatient Rehabilitation Facility (IRF) Services
- CMS Medicare Learning Network (MLN) Matters Special Edition (SE) 17036
Last Updated Mon, 19 Dec 2022 15:51:51 +0000