AARC Addresses Provision of RT Services in CORFs

August 24, 2007

The Centers for Medicare and Medicaid Services (CMS) is proposing Medicare Comprehensive Outpatient Rehabilitation Facilities (CORFs) changes that would negatively impact the ability of respiratory therapists to render diagnostic services and perform patient assessments for CORF beneficiaries.

Specifically, CMS is proposing to clarify the definition of respiratory therapy services by removing services in the current definition that CMS believes should only be provided by a physician and are inappropriate to include in a respiratory therapy plan of care. 

The AARC believes CMS may be unaware that the proposed revisions have the unintended consequence of eliminating certain provisions of respiratory services that are at the core of the respiratory therapy profession. We have issued extensive comments explaining these consequences, concluding with the recommendation that CMS:

• Remove the restriction that the respiratory plan of treatment be established entirely by the physician, and
• Permit physicians to work with respiratory therapists who will provide the actual therapy when establishing patient care plans for respiratory therapy services furnished in CORFs. 

The proposed changes are included in CMS’s annual proposed rule addressing 2008 payment rates and issues for physician services. Final rules should be issued by the end of the year, and at that time we should know if CMS has accepted our well reasoned and documented recommendations.

You can read the entire AARC comments.