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CMS Clarifies Role of Respiratory Therapy in the IRF Setting

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August 18, 2009

The Centers for Medicare and Medicaid Services (CMS) recently revised its coverage policies regarding patient selection and care requirements for those Medicare beneficiaries who need intensive rehabilitation services provided in the Inpatient Rehabilitation Facility (IRF) RF setting.

CMS noted that respiratory therapy can be a covered service if the need is well-documented and if it is ordered by the physician.

According to CMS, patients in these settings have more severe and more complex medical conditions that need more intensive services than those in other settings, such as skilled nursing facilities or in the home health setting. The four primary types of therapy provided in an IRF are physical therapy, occupational therapy, speech-language pathology, and prosthetics/orthotics therapy. The coverage policies, together with updated payment rates become effective January 1, 2010.  (Federal Register Notice: Federal Register Contents, Friday, August 7, 2009).

Due to the intense level of rehabilitation services needed to meet the IRF requirements, RTs working in this setting represent only a small segment of the profession overall. Nevertheless, RTs can and do provide skilled pulmonary rehabilitation to patients based on the individual’s plan of care in this setting.  We were concerned that the changes CMS initially proposed to existing policy could cause contractors to dismiss the value of RT services and exclude them from being covered as part of the bundled payment to the facility.

Responding to one of our state society leader’s inquiry as to the role of RTs in the IRF setting, the AARC asked CMS for clarification in the final rule as to whether respiratory therapy services could count toward the minimum guidelines which require 3 hours of therapy a day, 5 days a week. 

CMS acknowledged respiratory therapy as a Medicare covered service in the IRF setting “if the medical necessity is well documented by the rehabilitation physician in the medical record and is ordered by the rehabilitation physician as part of the overall plan of care for the patient.” However, CMS noted it would not add respiratory therapy services to the mandatory list because RT services may be beneficial to some, but not all, patients as an adjunct to the other primary types of therapy services noted above.

In the end, CMS is leaving it up to the individual facility to determine whether offering respiratory therapy or other non-core services is the best way to achieve the desired patient care outcomes.