REHAB AGENCY - BECOMING ONE, STAYING ONE
By Larry Fronheiser, Past President
Since the passage of the Balanced Budget Act in the summer of 1997,
perhaps the most frequently asked question of me as president of NARA
is, "What is the future of rehabilitation agencies?" That question was
also brought up frequently at our most recent conference in Washington,
DC. I have basically given the same advice to all existing and
potential NARA members when asked, and I will try to articulate those
comments to you.
To my knowledge, there are currently no regulations
being considered by HCFA that would eliminate certification of
rehabilitation agencies in the Medicare program. In fact, rehab
agencies have been "grouped" with other outpatient physical therapy
providers (OPTs) in most of the Balanced Budget Act provisions. In my
opinion, this grouping is probably good because it sends the message
that, until and unless Congress and/or CMS decide to eliminate
outpatient providers in general, it is unlikely rehabilitation agencies
would be targeted. Therefore, I think we can conclude our status as
certified rehabilitation agencies, within the Medicare program, is
relatively assured but not guaranteed.
If one is already a rehabilitation agency, then the
investment to become one is a financial expense of the past and should
not necessarily be considered as an unnecessary expense for the future.
Maintaining rehab agency status is neither an administrative nor
financial nightmare for most existing agencies. In my mind, the name of
the game in the future is to maintain flexibility. This concept has
merit if you consider the following:
- Rehabilitation agencies have "credentialing" status,
i.e., they are certified by the Medicare program and, at least
theoretically, are visited by state surveying entities on an annual
basis. This credentialing process gives both quality and marketing
advantages to those businesses who use credentialing as a competitive
advantage or as a mechanism for certification for many managed care
organizations.
- While it is anticipated that there may be changes in
the regulations for physical and occupational therapists in independent
practice (PTIP/OTIP), the fact remains that today neither of those
entities can provide additional services or function in multiple
clinics without being on-premise during the treatment of a Medicare
patient. Even if the on premise rules are changed, the ability to
provide multidisciplinary services is difficult for both PTIPs and
OTIPs.
- Many states tie reimbursement for auto coverage and
workers' compensation to Medicare rates. So far, it has been a
financial advantage in many states for rehabilitation agencies to
receive a higher rate of compensation in those cases.
- The home care industry is in a state of flux. It is
very possible many small home care agencies will be unable to service
their existing patients and the ability for a rehab agency to provide
home care on a direct bill basis is still viable.
- It is also possible that many smaller skilled nursing
facilities may decertify from the Medicare program when they recognize
the difficulties of the prospective payment system and consolidated
billing. Rehabilitation agencies will be in a significant position to
continue billing directly for those patients, serving as an outside
contractor for the nursing facility that chooses to decertify.
- The assisted living environment is a growing market
throughout the country. Many of these facilities are not associated
with a certified SNF and, therefore, require therapy services from an
entity that is capable of billing the Medicare program. Rehabilitation
agencies are clearly in a position to provide that service.
- Many of you may have thought of other competitive
marketing reasons to remain a rehabilitation agency; those nonmembers
who are reading this article may consider rehabilitation agency status
for one or more of the above reasons. Many of these same reasons apply
to comprehensive outpatient rehabilitation facilities (CORFs), and many
CORFs are currently joining NARA. For current NARA members, I would
encourage any of you who are considering decertification to at least
consider all of these elements before making the final decision.
As always, the American business community finds ways to deal with
adverse situations. Using the old cliche "There is no such thing as a
problem- only a new opportunity," I would encourage all of you to
consider the above reasons as we move forward as NARA members with our
continuing motto of "Strength through professional unity."