Late this afternoon, the Centers for Medicare and Medicaid Services (CMS) issued new guidance to inpatient rehabilitation facilities (IRFs) that provides additional clarification on flexibilities being afforded in response to the COVID-19 pandemic and also confirms that team meetings can be performed virtually. CMS will allow all forms of social distancing precautions when holding interdisciplinary team meetings and stressed electronic or virtual team meetings would be the safest during this pandemic.
In addition to CMS exercising their regulatory flexibility to waive the 60 percent rule, they are also waiving IRF coverage and classification requirements if the following criteria are satisfied:
- Patient is admitted to a freestanding IRF to alleviate acute care hospital bed capacity issues
- IRF is located in an area that is in Phase 1 or has not entered Phase 1 as noted in Guidelines: Opening Up America Again
CMS also provides additional information on the codes that should be used when IRFs are utilizing flexibilities that CMS has issued. CMS directs IRFs to add the following letters at the end of the unique hospital patient identification number (or medical record number in the IRF) to identify the patients eligible for each waiver:
- D – 60 percent rule
- DS – Coverage and classification requirements
- DDS – Both 60 percent rule and coverage and classification requirements