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Appeal guide · Inpatient rehab

Inpatient rehabilitation denials

Inpatient rehabilitation facility (IRF) stays are denied at admission or cut short mid-stay, usually on the argument that a lower level of care such as a skilled nursing facility would do. The appeal turns on the medical record showing why intensive, physician-supervised rehabilitation is required.

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What gets denied

  • IRF admission after stroke, brain injury, spinal cord injury, hip fracture, or major joint replacement
  • Continued-stay days once the plan decides goals can be met at a lower level of care
  • Transfer from an acute hospital to IRF instead of a skilled nursing facility
  • Rehab after cardiac surgery, transplant, or prolonged ICU stay (deconditioning)

Common denial reasons

  • Plan says a skilled nursing facility or home health is 'the appropriate level of care'
  • Therapy intensity (3 hours a day) is judged not tolerable or not required
  • No documented need for daily physician supervision
  • Pre-admission screening or physician certification missing from the record
  • Medicare Advantage plan applied internal criteria beyond the IRF rule

How we approach the appeal

Get the rehabilitation physician's admission note, the pre-admission screening, and the therapy evaluations. Map each element of the IRF criteria to a page in the record: multiple disciplines, intensity, medical supervision, expected improvement. For Medicare Advantage, cite 42 CFR 422.101(b)(2), which binds the plan to traditional Medicare coverage rules. If the patient is already admitted and the plan is ending coverage, use the fast-track review (see Timing) before the effective date so services continue during review.

Filing window

Medicare Advantage: request reconsideration within 65 days of the notice; expedited decisions within 72 hours (42 CFR 422.582, 422.584). When an IRF stay is being ended, the facility issues a Notice of Medicare Non-Coverage and the patient can ask the QIO for fast-track review by noon of the day before coverage ends (42 CFR 422.626). Commercial and employer plans: at least 180 days to file an internal appeal; urgent pre-service decisions within 72 hours (29 CFR 2560.503-1; 45 CFR 147.136).

Typical recovery

An IRF stay is billed per day at rates that make even a short denied stay a significant sum; the amount at stake depends on the length of stay and the plan's allowed amount.

Documents we'll ask for
  • · The denial or non-coverage notice with its effective date
  • · Rehabilitation physician admission note and pre-admission screening
  • · PT, OT and speech therapy evaluations and daily notes
  • · Acute hospital discharge summary
  • · Any plan-issued clinical criteria (request them in writing)

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This page provides general information about appeal strategy. It is not legal advice. Outcomes depend on documentation, plan terms, and timing.