Eli's Rehab Report

Question: I manage an acute inpatient rehab department, and we had a CMS survey last summer. All was good, except the surveyors said that a physician needed to sign off all physical therapy, occupational therapy, and speech-language pathology treatment plans. I have never had to get an inpatient therapy treatment plan signed off. Is this something new? Our orders just say evaluate and treat.

-- California Subscriber

Answer: Physicians do not need to sign off therapy plans of care for acute care or IRF therapy patients. Below are two links regarding therapy plans of care (POCs) in the acute inpatient hospital. The first link is the Condition of Participations for rehab services in the hospital:

• http://edocket.access.gpo.gov/cfr_2008/octqtr/pdf/42cfr482.56.pdf. In this section, CMS references 409.17 which you can find here:

• http://edocket.access.gpo.gov/cfr_2008/octqtr/pdf/42cfr409.17.pdf. As you can see, nowhere in 409.17 does CMS state that a physician must sign the therapy specific POC.

Ask the surveyor to show you the CMS regulation that states physicians must sign off POCs.

Important: Make sure your state does not have stricter requirements. Also, be aware that starting Jan. 2010, the newest IRF PPS goes into effect and has many new administrative requirements for IRF admissions that have much higher physician involvement.

For example, CMS will require a preadmission screening, and if the screening is completed by a clinician, the rehabilitation physician must document his or her concurrence with the findings. In addition, a specialized rehab physician must order the IRF services and is responsible for the final decisions on the patient's treatment.