Rehabilitation Nursing Criteria for Determination and Documentation of Medical Necessity in an Inpatient Rehabilitation Facility
The objective of this Position Statement is to establish and present a set of appropriate guidelines that define the criteria of 24 hour availability of rehabilitation nursing with specialized training or experience in rehabilitation for determination of medical necessity in an inpatient rehabilitation facility (IRF).
In order for a freestanding rehabilitation hospital or a rehabilitation unit of an acute care hospital to be classified as inpatient rehabilitation facility (IRF), they must meet the requirements specified in Title 42 Code of Federal Regulations (CFR) 412.23(b)(2), as well as other regulatory requirements and are paid under the IRF prospective payment system (PPS). Numerous fiscal intermediaries (FIs) monitor and determine if an IRF met the requirements specified in 412.23(b)(2). IRF care is only considered by Medicare to be reasonable and necessary under 1862(a)(1)(A) of the Social Security Act if the patient meets all of the requirements outlined in 42 CFR §§412.622(a)(3), (4), and (5).
The Medicare Benefits Policy Manual was revised, effective January 2010 with an update effective January 2014 to include documentation contained in the medical record that determined that an IRF admission is reasonable and necessary, with a focus on the preadmission screening, the post-admission physician evaluation, the overall plan of care and admission orders.
Decisions to admit a patient to an IRF are complex and based on multiple factors, including policy, regulatory standards, and assessment of each beneficiary's individual care needs. In 1982, the Health Care Financing Administration (HCFA), now the Centers for Medicare and Medicaid Services (CMS), identified Conditions of Participations (CoP) that had to be met in order to be classified as an IRF.
The inpatient rehabilitation facility (IRF) benefit is designed to provide intensive rehabilitation therapy in a resource intensive inpatient hospital environment for patients who, due to the complexity of their nursing, medical management, and rehabilitation needs, require and can reasonably be expected to benefit from an inpatient stay and an interdisciplinary team approach to the delivery of rehabilitation care.
In addition, in order for IRF patients to be considered reasonable and necessary, there must be a reasonable expectation that these criteria are met at the time of admission:
Interdisciplinary services are those provided by a treatment team in which all of its members participate in a coordinated effort to benefit the patient and the patient’s significant others and caregivers. Interdisciplinary services, by definition, cannot be provided by only one discipline. Though individual members of the interdisciplinary team work within their own scopes of practice, each professional is also expected to coordinate his or her efforts with team members of other specialties, as well as with the patient and the patient’s significant others and caregivers. The purpose of the interdisciplinary team is to foster frequent, structured, and documented communication among disciplines to establish, prioritize, and achieve treatment goals.
At a minimum, the interdisciplinary team must document participation by professionals from each of the following disciplines (each of whom must have current knowledge of the patient as documented in the medical record at the IRF):
• A registered nurse with specialized training or experience in rehabilitation;
• A social worker or a case manager (or both); and
• A licensed or certified therapist from each therapy discipline involved in treating the patient.
The criteria for IRF are subject to Local Coverage Determination (LCD) policies meant to help FIs define medical necessity for beneficiaries within a specific geographic area. The LCDs and IRF medical necessity criteria vary by agent and have become a major tool for allocating health care resources.
The Association of Rehabilitation Nurses (ARN) is pleased to provide this position statement to CMS regarding the criteria of 24 hour availability of rehabilitation nursing with specialized training or experience in rehabilitation for determination of medical necessity in an IRF and recognizes that CMS has a central role to play in improving rehabilitation care of individuals with chronic illness and physical disabilities. ARN is a professional nursing specialty association of more than 5,000 professional nurses, which is responsible for establishing the scope of rehabilitation nursing practice and for setting standards for professional rehabilitation nursing practice. ARN's mission is to promote and advance professional rehabilitation nursing practice through education, advocacy, collaboration, and research to enhance the quality of life for those affected by disability and chronic illness.
Set out below is ARN’s position statement, a summary of our major recommendations, followed by a rationale for the recommendations.
The Association of Rehabilitation Nurses (ARN) believes that the recovery from an acute episode of illness or injury depends on adequate medical treatment and early identification of needs for rehabilitation care. ARN believes that IRFs are a part of the quality care continuum and that individuals can benefit from rehabilitation nursing at any stage of the life span. It is ARN’s belief that the determination of need for intensive rehabilitation should be more dependent on the effects of a patient’s injury or illness (impairments, functional deficits, achievable goals) and not on the diagnosis.
Rehabilitation nurses, through specialty knowledge and expertise, promote and maintain the patient’s level of functioning. Although the proportions of skill mix of licensed and unlicensed staff must be appropriate and determined by the number of patients; levels of intensity of the patients for whom care is being provided; contextual issues including architecture and geography of the environment and available technology; level of preparation and experience of those providing care and accreditation standards, ARN believes a facility must employ registered nurses certified in rehabilitation nursing (CRRN) to improve a patient’s progress, thereby decreasing length of stay and resulting in a cost reduction. Certification in rehabilitation nursing is professional recognition of knowledge and skills in this specialty practice. It is ARN’s belief that IRFs must utilize the expertise of a CRRN for the supervision, orientation process, competency evaluation, and education of staff. ARN believes that the expertise of a certified rehabilitation registered nurse must be available in the assessment, implementation, and evaluation of a rehabilitation program to meet the needs of the rehabilitation population being served. Ultimately, ARN believes that accountability and coordination of cost-effective quality rehabilitation care is best accomplished by registered nurses who have been educated and certified in the rehabilitation specialty.
The rehabilitation nurse, easily accessible to individuals, families, team members and other concerned parties, and by virtue of specialized education, expertise, and interest in caring for individuals with chronic illness and disabilities, is a key partner in a successful rehabilitation program. ARN believes the outcomes of rehabilitation are maximized when the rehabilitation nurse takes a leadership role and collaborates with rehabilitation team members.
ARN believes that the 2008 Standards and Scopes of Rehabilitation Nursing Practice should be implemented and evaluated to improve the quality of care for rehabilitation patients. ARN supports the development and implementation of a standard patient assessment screening tool across the post acute care continuum based on patient needs that will measure the effectiveness of post acute care and provide outcome data to determine the appropriate post acute care setting at the appropriate time thus improving both quality of care and continuity of care in a cost effective manner. Lastly, ARN believes the documentation of the rehabilitation professional registered nurse should reflect the need for specialized rehabilitation nursing and should include the identification of relevant International Classification of Functioning, Disability and Heath (ICF) components and
ARN recommends CMS:
Rationale with Recommendations
Demographic shifts towards an increase in the population of elderly in the United States indicates a substantial increase in the number of people experiencing physical or mental impairments and the proportion of the population at risk of developing a physical or mental impairment that affects their functional ability. The percentage of the population aged 65 and over will increase from approximately 12 percent in 2005 to almost 20 percent by 2030 (United States Census Bureau, 2013). This shift will affect the way the health care industry does business. Aging consumers with a disability will require service from various health care agencies, resulting in a sharp increase in the need for quality rehabilitation and disability-related services.
Recent military conflicts have added many more individuals to the population who need rehabilitation services affecting both military and civilian rehabilitation service providers. Rehabilitation nurses have specialty knowledge and must stay abreast of the new treatments and advances in rehabilitation health care, polytrauma, and post traumatic stress syndrome.
Rehabilitation can take place in various settings including at home through the Medicare home health benefit (including hospice), in an out-patient therapy facility, in a skilled nursing facility (SNF), in a comprehensive outpatient rehabilitation facility (CORF), in an inpatient rehabilitation facility (IRF), or in a long-term care hospital (LTCH).
Goal and Role of Rehabilitation Nurse
Scope and Standards of Practice
Generalist Rehabilitation Nurse with Specialized Knowledge
The rehabilitation nurse exemplifies a specialized knowledge and skill set that is comprehensive and broad in scope with roots in both professional nursing and rehabilitation functional care concepts. In addition to administering specialized nursing care, the rehabilitation nurse spends a significant amount of time reinforcing patient learning from other disciplines. It is essential that all professional registered nurses practicing rehabilitation nursing possess the basic knowledge and skills that enable them to collect appropriate assessment data for each rehabilitation patient; identify significant problems; establish appropriate diagnoses; and set short and long term goals and identify outcomes that reflect an understanding of the impact of the disability or chronic illness on the planning, delivery, and evaluation of care within the limits of the available economic resources.
Certified Rehabilitation Registered Nurse (CRRN)
Documentation should include the following as appropriate, yet not be limited to:
Goals and interventions that integrate and demonstrate carryover of techniques from therapy to increase the functional status and lessen the burden of care should also be evident in the medical record.
Consideration should be given as to how the medical and functional components of the rehabilitation patient are inter-related and should be documented from the rehabilitation nursing perspective. Education of the patient and family are inherent within rehabilitation nursing; evidence of ongoing patient and family education for the above mentioned topics should be documented by the rehabilitation professional registered nurse in the medical record.
CMS requires that the IRF patient assessment instrument (IRF-PAI) is included in the IRF medical record. Because the information in the IRF-PAI must correspond with information provided in the medical record, nursing documentation is vital to supporting the burden of care for medical and functional complexity of the patient.
Frequent conflicting documentation between disciplines, widely fluctuating patient abilities throughout a 24 hour period based upon changes in medical stability, pain, endurance or cognition, or failure to progress as planned should be explained and a realistic plan to address the problem(s) identified. Documentation of discharge plans should be indicated early in the plan of care.
The International Classification of Functioning, Disability and Heath (ICF) is part of the international classification systems developed by the World Health Organization (WHO). The ICF has a focus on human functioning, providing a unified, standard language and framework that facilitates the description of the components of functioning that are impacted by a health condition. While it is not an assessment tool, it does allow the collection of data as to how people with a health condition function in their daily life rather than focusing on their diagnosis or the presence or absence of disease. The ICF describes the situation of the individual within health and health-related domains and within the context of environmental and personal factors.
The ICF is WHO's framework for measuring health and disability at both individual and population levels. It has been tested for cross-cultural applicability in over 40 countries. The ICF integrates the social and environmental aspects of disability and health and provides a framework that is equally applicable for mental and physical disorders. Thus, it has great potential as a common global framework for organizing and communicating information on human functioning
Some of the Medicare Fiscal Intermediaries (FIs) use the ICF framework and its concepts for Medical Review. The medical reviewers use the ICF framework to adjudicate claims for complex clinical scenarios. This systematic process helps ensure that relevant pieces of information in the health record are identified and considered during the medical review process. Documentation by the rehabilitation nurse should include the identification of relevant ICF components and domains, a description of how they manifest clinically, clinical interventions implemented to address the identified categories, and relevant outcomes.
Rehabilitation is a continuous process and patients rehabilitate themselves through the influence of the comprehensive approach to care provided by the rehabilitation professional registered nurse. To achieve optimal effectiveness, today’s rehabilitation professional registered nurses need to be cognizant of patients’ needs and desired outcomes, concerns about cost containment, and the service options available along the continuum of care. Over the next few decades, the number of people with chronic illness and disability are expected to rise. This shift will increase the demand for the knowledge and expertise of rehabilitation professional registered nurses. These rehabilitation professional nurses providing health care need to conform to the highest uniform national standards available, ensuring that the continued health and safety of the public are protected and that the care provided is cost-effective in the most appropriate setting and of the highest quality.
With a core purpose to promote and advance professional rehabilitation nursing practice, ARN developed this position statement to provide CMS and the FIs with guidelines that could assist in standardizing the language of the LCDs and assist in further defining the criteria of 24 hour availability of rehabilitation nursing with specialized training or experience in rehabilitation for determination of medical necessity in an IRF. ARN appreciates CMS's continuing efforts to ensure that Medicare beneficiaries have access to high quality care in the most appropriate setting and ARN encourages CMS and other insurers to utilize these guidelines in support of continuing efforts to recognize the value of intensive inpatient rehabilitation professional nursing in ensuring safe, high-quality standards.
American Nurses Association. (2010b). Nursing: Scope and Standards of Practice. Silver Spring, MD: Author.
American Nurses Association. (2010a). Recognition of a Nursing Specialty, Approval of a Specialty Nursing Scope of Practice Statement, and Acknowledgement of Specialty Nursing Standards of Practice. Silver Spring, MD: Author.
Association of Rehabilitation Nurses. (2008). Standards and Scope of Rehabilitation Nursing Practice. Glenview, IL: Author.
Association of Rehabilitation Nurses. (2011). The Specialty Practice of Rehabilitation Nursing: A Core Curriculum (6th ed.). Glenview, IL: Author.
Centers for Medicare and Medicaid Services. Medicare Benefit Policy Manual, Chapter 1-Inpatient Hospital Services Covered under Part A (Rev 179, 01-14-2014), pg. 23-29. Retrieved from https://cms.hhs.gov/Regulations-and Guidance/Guidance/manuals/Download/bp102c01.pdf.
Centers for Medicare and Medicaid Services. GPO Access Electronic CodeofFederalRegulations. Title 42: CFR Public Health,PART 412—PROSPECTIVE PAYMENT SYSTEMS FOR INPATIENT HOSPITAL SERVICES, Subpart B—Hospital Services Subject to and Excluded from the Prospective Payment Systems for Inpatient Operating Costs and Inpatient Capital-Related Costs, § 412.23 Excluded hospitals: Classifications. Retrieved from: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr;rgn=div5;view=text;node=42%3A126.96.36.199.12;idno=42;sid=983714f49407a4746803231698d66b4c;cc=ecfr#42:188.8.131.52.184.108.40.206.
Nelson, A., Powell-Cope, G., Palacios, P., Luther, S. L., Black, T., Hillman, T., Christiansen, B., Nathenson, P. & Gross, J. C. (September/October 2007). Nurse Staffing and Patient Outcomes in Inpatient Rehabilitation Settings. Rehabilitation Nursing, 32 (5).
United States Census Bureau. (2013). 2012 National Population Projections. Retrieved from http://www.census.gov/population/projections/data/national/2012.html.
Association of Rehabilitation Nurse. The Rehabilitation Staff Nurse Role Description (Brochure).
Association of Rehabilitation Nurses. Rehabilitation Nurses Make a Difference (Brochure).
Association of Rehabilitation Nurses. Factors to Consider in Decisions about Staffing in Rehabilitation Nursing Settings (Position Statement).
Centers for Medicare and Medicaid Services. (2013). Inpatient Rehabilitation Facility Prospective Payment System. Available at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/InpatRehabPaymtfctsht09-508.pdf.
Commission on Accreditation of Rehabilitation Facilities. (2008). Standards Manual and Interpretive Guidelines for Medical Rehabilitation. Tucson: CARF.
Institute of Medicine Report (2003). Enabling America: Assessing the Role of Rehabilitation Science and Engineering. Available at http://books.nap.edu/catalog/5799.html
Approved April 2008; revised March 2014.
Download PDF version.