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A general Medicare threshold for establishing the need for inpatient rehabilitation facility (IRF) services is that the patient must require and receive at least three hours of therapy per day. National Government Services, Inc., a Medicare intermediary with jurisdiction in 18 states (California, Connecticut, Delaware, Hawaii, Illinois, Indiana, Kentucky, Massachusetts, Maine, Michigan, New Hampshire, Nevada, New York, Ohio, Virginia, Vermont, Wisconsin, and West Virginia) released a Local Coverage Determination (LCD), effective December 1, 2007, that does not allow group therapy services to contribute to the "three hour rule."
We believe the exclusion of group treatment is unjustified because such services are efficacious. While the Centers for Medicare and Medicaid Services (CMS) has no position on this interpretation, it does allow every minute of group treatment in skilled nursing facilities to be counted toward meeting Resource Utilization Group (RUG) minimum requirements. ASHA is joined by the American Occupational Therapy Association and American Physical Therapy Association in contesting this local interpretation. For further information, please contact reimbursement@asha.org.
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