3 hour rule and HCFA

[Guest guest]

Jeff Geyer writes <With regard to this three hour rule : Only PT/OT treatment time satisfies this rule, which is intended as an indicator of required intensity of service for medical rehab as well as the threshold of activity tolerance for admission>

Actually, the above statement is incorrect. The HCFA hospital manual section on inpatient rehabilitation, states:

" Relatively Intense Level of Rehabilitation Services. The general threshold for establishing the need for inpatient hospital rehabilitation services is that the patient must require and receive at least 3 hours a day of physical and/or occupational therapy. (The furnishing of services no less than 5 days a week satisfies the requirement for " daily " services.) While most patients requiring an inpatient stay for rehabilitation need and receive at least 3 hours a day of physical and/or occupational therapy, there can be exceptions because individual patient's needs vary. In some instances, patients who require inpatient hospital rehabilitation services may need, on a priority basis, other skilled rehabilitative modalities such as speech-language pathology services, or prosthetic- orthotic services and their stage of recovery makes the concurrent receipt of intensive physical therapy or occupational therapy services inappropriate. In such cases, the 3-hour a day requirement can be met by a combination of these other therapeutic services instead of or in addition to physical therapy and/or occupational therapy. An inpatient stay for rehabilitation care can also be covered even though the patient has a secondary diagnosis or medical complication that prevents him from participating in a program consisting of 3 hours of therapy a day. Inpatient hospital care in these cases may be the only reasonable means by which even a low intensity rehabilitation program may be carried out. Document the existence and extent of complicating conditions affecting the carrying out of a rehabilitation program to ensure that inpatient hospital care for less than intensive rehabilitation care is actually needed. "

This last section also refers to the flexibility that has always existed in the 3 hour rule. None of this is supposed to change with the advent of IRF PPS. There is nothing in this section of the HCFA manual that refers to group treatments. Other intermediaries may follow different rules than those outlined by HCFA.

Ann Skinner OTR

OT Coordinator

ECRC