In a recent RACMonitor.com article on The Curious Case of the CORF the CORF was described as an “orphan” program that had conflicting regulatory advice for providers in recent years. The Conditions of Participation, the State Operations Manual Interpretive Guidelines, and various instructions from the Medicare Contractors (fiscal intermediaries and MACs) put the provider at a disadvantage. Many long-time rehab providers with Medicare certification as a CORF found that claims were being denied based upon the confusion between the requirement that the physician “wholly” develop the plan of care in a respiratory CORF and the requirement that the physician develop the plan of care in a physical therapy CORF. Implicit in the physical therapy CORF is that the physical therapist will provide input from the therapy evaluation to develop (or develop in concert with the physician) the CORF plan of care. What is different about the CORF is that that therapy cannot begin until the plan of care is certified, whereas in other outpatient rehab settings there is a timeframe of up to 30 days for the physician to certify the plan of care.
For current CORFs providing respitory therapy programs, it is imperative that the plan of care for respiratory therapy be wholly developed by the physician (this can be the referring physician, or the CORF medical director). For physical therapy programs in a CORF it is equally imperative that providers understand that the plan of care must be certified prior to therapy commencing, and that includes provding any services on the day of the evaluation other than the evaluation.
For all CORFs, as you get prepared for review under the Recovery Audit Contractor (RAC) program, make sure that you have all your regulatory reference material pulled together, particularly as it relates to the particular time period that is under review. The RAC look-back period is 3 years, but no earlier than October1, 2007. Scrapbooking your way to success is a good way to get started.