Rehab Agencies (sometimes known as “ORFs”) and Comprehensive Outpatient Rehabilitation Facilities (CORFs) are still listed as a Tier 4 priority in Medicare’s survey and certification priorities. New providers are finding that their initial application with their fiscal intermediary or Medicare Administrative Contractor (MAC) may have been approved, but their State Agency that is contracted to do new provider surveys have had their hands tied by budget cuts over the past several years.
One option is to write your State Agency as well as the CMS Regional Office to request an exception based upon medical necessity. For example, if in your geographic area there is not enough availability of physical, occupational or speech therapy services on an outpatient basis, it may be shown to be detrimental to Medicare beneficiaries in need of these outpatient rehab therapy services. Members of the National Association of Rehab Agencies and Providers (NARA) have reported some success in this regard, but have also reported that some State Agencies are quick to deny this request.