AAPM&R has partnered with the American Medical Rehabilitation Providers Association (AMRPA) and the Federation of American Hospitals (FAH) on an innovative project with the HHS Office of Inspector General to address wide variations in error rates found by CMS contractors and OIG on Medicare IRF claims over the past 15 years. The three organizations are providing data and feedback to OIG as the agency conducts a nationwide audit of IRF claims. A previous nationwide audit by OIG published in 2018 found an 84% error rate. At the time, AAPM&R strongly challenged that finding and continued a dialogue with OIG which has led to this initiative.
After months of preparation and review of actual patient cases, the IRF stakeholders recently met with the OIG, its audit contractor, Performant, and CMS officials to discuss medical necessity and documentation requirements in connection with this new audit. A panel of IRF stakeholders, including rehabilitation physicians and clinicians, association leaders, and legal counsel participated in a wide-ranging dialogue with OIG and its audit contractor, Performant, in an effort to identify key issues that lead to denials of IRF claims. Government auditors and IRF stakeholders exchanged views and shared different perspectives on a wide variety of IRF medical necessity and documentation requirements with the goal of gaining consensus on areas in need of additional attention to reduce error rates.
OIG is expected to draft its report on this nationwide IRF audit over the next several months and AAPM&R and the other IRF stakeholders will be able to respond to the draft report before it is published. The written response will be published as an addendum in the final OIG report, which is expected within the next year.