A common question we get asked a lot is the difference between a CORF and a Rehab Agency. In Part One, we’ll examine their definitions as well as their differences. In Part Two, we’ll discuss the billing requirements of both.
A CORF (comprehensive outpatient rehabilitation facility) is a federally certified non-residential facility that provides outpatient diagnostic, therapeutic and restorative services for the rehabilitation of a patient’s injury, disability or disease. The CORF must provide a comprehensive, coordinated skilled rehabilitation program for its patients that include, at minimum:
These are physician-performed services that are administrative in nature, such as consultation with, and medical supervision of, non-physician staff; patient case review conferences; utilization review; the review of the therapy/pathology plan of treatment, as appropriate; and other facility medical and administration activities necessary to provide skilled rehabilitation services (those that PTs, OTs, SLPs and RTs provide), and other services that directly relate to the rehabilitation plan of treatment.
Please note that diagnostic or therapeutic services that a CORF (or other) physician provides to a CORF patient are NOT CORF physician services. These services are separately payable to the physician under the MPFS, at the non-facility payment amount billed as if provided in the physician’s office. Remember that to become a CORF patient, a beneficiary must be under the care of a physician who certifies that he/she needs skilled rehabilitation services. If the referring physician does not specify the rehabilitation goals for PT, OT, SLP, or RT services, the CORF physician must established them. Further, either the referring physician or the CORF physician must establish, and sign, a rehabilitation plan of treatment prior to the beginning treatment.
In addition, the CORF physician or the referring physician, must review the treatment plan for respiratory therapy services at least every 60 days; and for physical therapy, occupational therapy, speech-language pathology, and for all other services at least once every 90 days; certifying that the plan is being followed and that the patient is making progress in attaining the established rehabilitation goals.
It is important to remember that the CORF physician must be present in the facility enough to ensure that CORF services are provided in accordance with accepted principles of medical practice, medical direction, and medical supervision.
These services should comprise a clear majority of the total CORF services. To supervise CORF physical therapy services, the physical therapist must be on the CORF premises (or must be available to the physical therapy assistant through direct telecommunications for consultation and assistance) during the CORF’s operating hours
These services are covered only if the patient’s physician (or CORF physician) establishes that the services directly relate to the patients' rehabilitation plan of treatment and are needed to obtain the rehabilitation goals. Social and psychological services include only those services that address the patient’s response and adjustment to the rehabilitation treatment plan; rate of improvement and progress towards the rehabilitation goals; or other services as they directly relate to the physical therapy, occupational therapy, speech-language pathology, or respiratory plan of treatment.
In addition to the above three required core services, the CORF may also furnish the following other covered and medically necessary items and services; as long as they directly relate to, and are consistent with, the rehabilitation treatment plan, and are necessary to achieve the rehabilitation goals.
The CORF must have adequate space and equipment needed for any of the services provided. All services must be furnished on the premises of the facility, except in the cases of home evaluations.
Medicare certified Rehabilitation Agencies provide an integrated, multidisciplinary program designed to improve the physical function of individuals. At a minimum, the rehabilitation agency must provide physical therapy or speech pathology services. The services must be reasonable and necessary with a potential for improvement. Only restoration therapy is covered. The beneficiary must be under the care of a physician. Certification is achieved by submission of a completed application, required documentation and successful completion of a survey. There are no state licensing requirements imposed by the agency unless required by the Health Care Clinic Act.
A rehab agency is often referred to as an ORF (outpatient rehabilitation facility or other rehabilitation facility). They may also be known as an OPT/OST in CMS publications and federal regulations.
Another difference between CORFs and rehab agencies are in their plan of care. For a CORF, the referring physician must review the plan of treatment every 60 days. However, a rehab agency must have the doctor certify the plan of care every 90 days. For outpatient hospital-based therapy departments, re-certification for therapy should be performed every 90 days; however, it is acceptable for re-certification to be performed every 60 days.
CORF has been called an orphan rehab program because the regulations surrounding it never fully evolved. CORF providers have reported billing denials due to a conflicting set of guidelines and inconsistencies due to varying interpretations of the existing documentation.
While it is easy to mistake one for the other at the surface level, CORFs and Rehabilitation Agencies do serve different purposes and the rules and regulations surrounding each can vary. If you still have questions, please feel free to contact one of our helpful StrataPT representatives. They can show you why we are the industry leaders when it comes to an all-inclusive system that will take your PT/OT practice to the next level.