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How Long is a Week? Coverage Requirements that IRFs Need to Know

May 13, 2021
Compliance By Armi Hernandez, Consultant

On August 4, 2020, the Centers for Medicare & Medicaid Services (CMS) released the Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) final rule for FY 2021.

 

PAPE

 

On August 10, 2020, the Federal Register 48424, Volume 85, Number 154 published the Final Rule. Several changes went into effect on October 1, 2020. These included:

  • Removal of the Post-Admission Physician Evaluation (PAPE) as we knew it from Chapter 1 of the Medicare Benefit Policy Manual.
  • More flexibility for physicians to allow non-physician practitioners to perform duties previously required by the rehabilitation physician.
  • Changes to the definition of a “week” for the purposes of counting minutes and meeting deadlines.

Even though the PAPE is no longer required, LW Consulting, Inc. (LWCI) strongly believes that not all of the requirements are meant to go away. Here’s what can go:

  • The requirement for the first physician documentation to be completed within 24 hours of the admission.
  • A statement that the PAPE has been compared with the Pre-Admission Screen (PAS)

The first physician assessment (which replaces the PAPE) still must include:

  • Demonstration of medical necessity and the appropriate admission for the resident to the IRF.

The PAPE requirement change does not prevent an IRF from continuing with the best practice of evaluating the patient within the first 24 hours of admission if the patient's condition warrants a timely evaluation.

LWCI has developed a 13-Part General Inpatient Rehabilitation Facility Training Series that details the IRF coverage requirements. If you have any questions or would like an external review of a sample of your records completed during the COVID-19 parameters, LWCI will be glad to assist.

For more information, contact Jim Wright, Director by calling 717-213-3128 or email JWright@lw-consult.com.

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