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Comprehensive Outpatient Rehabilitation Facility

Can the facility solicit and treat non-Medicare patients?

Yes. Until September 2001, the CORF program was one of the last of the cost-based accounting programs. Reimbursement for services provided was determined by a complex formula that factored all the costs associated with facility operation and service provision. The intent was to operate in a non-profit, break even manner that discouraged treatment of non-Medicare patients.

Beginning in October of 2001, Medicare instituted a physician fee schedule (PPS- Perspective Payer System) that allows the facility to operate on a for profit basis. This change has opened the doors to treatment of non-Medicare patients outside the regulations and restrictions of the Medicare funded program. Regulations mandate establishment and notification of CORF operational hours (determined by the facility administration) during which time Medicare patients ONLY are to be treated, and the program rules and regulations are to be strictly adhered to. Outside of those delineated hours however, the clinic becomes an outpatient treatment facility available to any and all that may seek treatment or avail themselves of the services offered. This one key difference from the previous reimbursement system has exponentially expanded the available patient base and facility potential. No longer are the facilities considered Medicare only. Program guidelines provide for allowance of a dual-use facility, meaning the CORF may be established and operated inside a clinic or office being used for provision of other medical disciplines (chiropractic is the most common). Current front office staff may be utilized as well as the patient waiting area and entrance. There is no need for hiring additional reception personnel or establishing a separate entrance or waiting area. CORF patient files and records must be kept separate in a locked file cabinet. No commingling of records is permitted. There should be a separate corporate structure (C corp.) established (seek the advice of your accountant) as well as separate bank accounts, phone number, and corporate mailing address (PO Box).