Common Pitfalls to Avoid

Regardless of the circumstances, a lack of documented evidence that a patient's condition warranted rehabilitation services delivered in an acute care setting equates to a denial of payment from CMS for that service.

Medical Necessity

Definition: "A patient’s condition must require the 24-hr availability of a physician with special training or experience in the field of rehabilitation. This need should be verifiable by entries in the patient’s medical record that reflect frequent and direct, and medically necessary physician involvementin the patient’s care…”

Interpretation:  Active comorbidities that require a physician to evaluate, monitor and/or treat at time of admission and throughout the stay.

Rehabilitation Necessity

  • Functional limitations (At least 18 FIM items)
  • Reasonable expectation of progress
  • Plan of care –approved and updated
  • At least two disciplines of service

The Documentation Checklist -All Disciplines

  • Medical Necessity
  • Rehab Necessity
  • Coordinated Multidisciplinary Team Approach
  • Individualized Interdisciplinary Plan of Care
  • Three-Hour Rule
  • Skilled Therapy
  • Rehab Nursing
  • Patient Progress Toward Goals
  • Physician Leadership


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