Medicare Program Integrity Manual (Pub. 100-08), Ch. 6 § 6.7.1
Reviewing for Intensive Level of Rehabilitation Therapy Services
6.7.1 – Reviewing for Intensive Level of Rehabilitation Therapy Services
Requirements
(Rev. 10184; Issued: 06-19-2020; Effective: 07-21-2020; Implementation: 07-21-
2020)
When reviewing IRF claims, the UPIC, MAC, SMRC, CERT and RAC shall verify that
the IRF documentation requirements are met in accordance with IOM 100-02, Medicare
Benefit Policy Manual, Chapter 1, Section 110.
The UPIC, MAC, SMRC, CERT and RAC shall not make absolute claim denials based
solely on a threshold of therapy time not being met. When the current industry standard
of generally 3 hours of therapy (physical therapy, occupational therapy, speech-language
pathology, or prosthetics/orthotics) per day at least 5 days per week or at least 15 hours of
intensive rehabilitation therapy within a 7 consecutive day period is not met, the claim
shall undergo further review.
The UPIC, MAC, SMRC, CERT and RAC shall use clinical review judgment to
determine medical necessity of the intensive rehabilitation therapy program based on the
individual facts and circumstances of the case, and not on the basis of any threshold of
therapy time. The standard of care for IRF patients is individualized (i.e., one-on-one)
therapy. 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. However, MAC, SMRC, CERT and RAC shall not deny solely
because the situation/rationale that justifies group therapy is not submitted in response to
an ADR.