I get calls and inquiries asking “what is a rehab agency”. Generally people have heard that a rehab agency may be a more profitable outpatient model than private practice, or that supervision rules for assistants are more favorable. Some outpatient providers have been told by managed care payors that certification as a rehab agency or CORF is necessary and some States may require rehab agency or CORF certification as a condition of Medicaid enrollment.
What is A Rehab Agency: and Should I Look Into Becoming a Rehab Agency?
A rehab agency is a Medicare institutional provider that is subject to not only Medicare Conditions for coverage (CfC), but Conditions of Participation (CoP).
A rehab agency at a minimum:
- Provides an integrated interdisciplinary rehabilitation program designed to upgrade the physical functioning of handicapped disabled individuals by bringing specialized rehabilitation staff together to perform as a team; and
- Provides at least physical therapy or speech-language pathology services.
Conditions of Participation that Rehab Agencies must meet in order to begin and continue participating in the Medicare and Medicaid programs can be found in the Code of Federal Regulations. According to CMS, the CoP and the CfC represent health and safety standards which are the “foundation for improving quality and protecting the health and safety of beneficiaries.”
If you are considering becoming a rehab agency these are a just a few of the items that differentiate a rehab agency from a private practice:
- Medicare enrollment is via the CMS 855a form requiring an application fee for initial enrollment and revalidation, whereas there is no enrollment fee for private practice therapist or a physical and occupational therapy group practice. A physical or occupational therapist makes an initial enrollment via the CMS 855i form and reassigns benefits via the CMS 855r to the group practice (which has enrolled via the CMS 855b).
- Medicare survey and certification by the State Agency or an approved deeming authority is required to ensure compliance with the Conditions of Participation for rehab agencies. A private practice is not subject to conditions of participation, but for physical therapists a site visit is required for both enrolling therapists and enrolling group practices per the Affordable Care Act. A site visit is not required for an occupational therapist in private practice, unless a physical therapist is part of the enrolling group’s application.
- DME supplier enrollment for the purpose of fabricating and issuing hand therapy splints (billing L codes) is not required for a rehab agency, whereas in a private practice a DME enrollment must be completed (along with a fee) for each group practice location wishing to be certified as a DME supplier.
- Physical therapist assistants (PTA) and occupational therapy assistants (OTA) in a rehab agency are subject to general supervision requirements, which contrasts to direct supervision that is required in a private practice.
- A rehab agency is a participating provider, whereas a private practice has an option to be a non-participating provider.
- In a rehab agency the effective billing date is the date of a successful survey, in a physical therapy private practice the effective date of billing privileges is essentially the date of initial enrollment subject to claims time filing limitations. (there is much more on this topic to fully explain the underlying authority for billing privileges.)
These are just a few of the key differences, but don’t be tempted to become a rehab agency without understanding all the attendant requirements of being subject to the Conditions of Participation. Be ready to establish substantive policies and procedures, implement the policies and procedures, and conduct all the attendant mandatory meetings and reviews that are required and meet facility standards.
Are you interested in becoming a rehab agency? Do you want to learn more? Contact Nancy Beckley and Associates where both Nancy Beckley and Mark McDavid, OTR, RAC-CT are experts in rehab agency development, implementation and compliance. Both Nancy and Mark are on the Board of Directors of the National Association of Rehab Providers and Agencies (NARA) and have collectively assisted over 100 rehab agencies successfully develop their policies and procedures, successfully pass a state survey or an accreditation inspection and successfully complete corrective plans of action.