Medicare Compliance & Reimbursement

Rehab providers don't have long to meet the threshold.

Fiscal intermediaries will be tracking 75 percent rule compliance based on a 12-month review period that's different from many providers' cost-reporting period, warns consultant Ann Lambert Kremer with Baker Newman & Noyes in Portland, ME.

And since FIs need four months to review the results and alert the facility to any change in classification before its next cost-report period begins, some facilities will have a review period that doesn't provide for a full 12 months of data.

Specifically, facilities that have a cost reporting period that begins anywhere between July 1 and Nov. 1 will be judged on less than 12 months of data, because FIs have been instructed not to consider any data collected before the July 1 implementation of the final rule, the Centers for Medicare & Medicaid Services explains in the rule.

That means "everybody should begin tracking their compliance on July 1, regardless of their cost-reporting period," urges Kremer. "They shouldn't wait until the start of their cost-reporting period."

This could present a problem for facilities in areas that have markedly different populations depending on the season, such as Florida and Maine, Kremer notes. So it's important that those facilities realize they might not be reviewed on data from their busy times, "and make their admission decisions accordingly," she instructs.