Medicare Compliance & Reimbursement

CMS hints that IRFs are upcoding on a regular basis.

The Centers for Medicare and Medicaid Services anticipates aggregate payments to inpatient rehab facilities to increase, but CMS also proposed a 1.9 percent standard payment amount reduction based on evidence that "coding changes" caused unnecessary IRF payment increases.
 
In the 2006 proposed inpatient rehab facility payment rule published in the Federal Register, CMS dances around an outright accusation of upcoding, stating only once that "upcoding for higher reimbursement may be a factor," but its view is clear in this proposed rule.
 
And while upcoding charges aren't blatant in the rule, CMS makes its beliefs plain in a press release on the proposal: "Analysis clearly shows that upcoding in the first year of the PPS increased payments to providers by at least 1.9 percent, and as much as 5.8 percent. Because 1.9 percent is the minimum reduction justified by the data, the proposed rule requests comments on whether a larger adjustment is appropriate."