The OIG (Office of Inspector General) has released a 2019 Work Plan that includes an audit of Cardiac & Pulmonary Rehabilitation (CR/PR) services

Be aware that the OIG does not necessarily follow through on all audits included in the Work Plan but we want you to be aware.

A previous OIG audit of cardiac rehabilitation, mentioned in the above link, was conducted in 2015. It reviewed one hospital in New Jersey ( A significant number of deficiencies in both CR and PR programs in that institution were identified by the OIG.

A weekly subscription entitled Report on Medicare Compliance published by a commercial company, Health Care Compliance Association (HCCA), included an article that discussed Medicare/MAC audits of CR/PR and lessons learned. The content of the article reflects their interpretation and while there is some helpful advice in the article, AACVPR tells us that they offer the following clarification to CR and PR programs on these points from the article:

The PR Medicare provision (42 CFR 410.47) is correctly cited, stating that patients with moderate to very severe COPD (stages II-IV), are eligible for PR. There are inaccurate references to eligibility for patients with “moderate to severe” COPD elsewhere in the article.

Some PR programs document the CMS requirement for direct contact in PR with a physician signature on the monthly ITP that states, “I have seen this patient and I …” The article proposes adding a separate physician note in the chart specific to the initial direct contact and with every 30-day direct contact. This suggests one more form for documentation that is burdensome for programs and for the physician (work not billable by the physician). The ITP is the document CMS requires for documentation that can adequately serve this purpose.

The advice regarding staffing recommendations is concerning to NCCRA and AACVPR. Keep in mind that staffing ratios and personnel credentials may be subject to individual state laws. However, the current Medicare provisions for CR/PR and CMS’ response to public comments were published in the Federal Register in 2009. It is clear that CR/PR are multidisciplinary services.

From Federal Register, Vol. 74, No. 226, November 25, 2009:

pg 61877: “…may be part of the multidisciplinary team working with CR and ICR patients…”

pg 61880: “A PR program is typically a multidisciplinary program…”; “The plan is developed by a physician in conjunction with the interdisciplinary team.”

pg 61884: “Given that various individuals, acting under the supervision of a physician, can make up the PR multidisciplinary team…We believe these evaluations and individualized treatments are part of the PR, CR, or ICR program for those beneficiaries who need them. As such, we believe they should be conducted by one or more members of the multidisciplinary team of the CR, CR, or ICR program with the appropriate expertise.”

From Federal Register, Vol. 74, No. 223, November 20, 2009:

pg 60567: “We believe these evaluations and individualized treatments are part of the PR, CR, or ICR program…should be conducted by one or more members of the multidisciplinary team of the PR, CR, or ICR program with the appropriate expertise.” 

In fact, it is the multidisciplinary nature of CR and PR that strengthens the quality of the service provided to patients with many co-morbidities and educational needs. Each program director should strive to hire staff with the goal of having a well-rounded team. Local and institutional resources are unique to each program.

It is significant to point out that since the 1970’s when CMS (then HCFA) began covering and reimbursing for CR (and PR in 2010), neither CMS nor any MAC or auditor has questioned the qualifications of staff beyond the expectation for “qualified personnel” and CMS provides no further definition beyond that.

With the goal of identifying elements that would constitute “qualified staff”, AACVPR offers a voluntary professional certification (CCRP) for cardiac rehabilitation practitioners and a joint AARC/AACVPR certificate for pulmonary rehabilitation practitioners. There are over 900 CCRPs and this is a “preferred qualification” for CR practitioners, as outlined in the AACVPR Guidelines for Cardiac Rehabilitation and Secondary Prevention Programs (Human Kinetics, 2013). These certifications were developed from published core competencies and guidelines.

AACVPR also offers a voluntary program certification program that is based on scientific evidence, core program components, and regulatory compliance. CR and PR programs that have achieved and maintained certification status as well as rehabilitation programs that continually strive to incorporate current and best practices should be well prepared to face the rigors of an audit with confidence.

LCD Draft for SET


On May 17th Palmetto released their LCD draft for the SET (supervised exercise therapy) for the PAD population.  The open response period for comments is June 4 through July 19th.  Some of the NCCRA Board members met on Friday to discuss the draft and organize some suggestions and clarification on certain items such as frequency of MD signatures.  We, as an organization, plan to submit written comments to Palmetto by the July 19th deadline  In the meantime we wanted to let NCCRA members know we are working on this and would invite comments, questions and/or concerns on this draft that may add to our comments back to Palmetto.  Please contact your VP if you have any questions.*1&Cntrctr=392&s=14&DocType=All&bc=AAAAAAQAAAAA&




CMS has corrected the policy for SET

Good news!  CMS has corrected the policy for SET to include outpatient hospital settings as allowable.  Please review the following attachment.  You can also review updates on the AACVPR website.

MACs have until July 2nd to get ready to accept these claims.  We were told by Dr. Feliciano back in March that would could submit claims and that there would be no new LCD created unless it was warranted.   

Supervised Exercise Therapy MLN matters 5 17 18


Get to Know Your New Board Members

Welcome to our new board members!  We appreciate their willingness to serve!

Kelly Forrest, Coastal Vice President

I am a Registered Nurse of 20+ years.  I have worked in Cardiac Rehab for the pas seven years at CarolinaEast Medical Center in New Bern.  I have two children, my daughter Chandler is 23 and my son Tyler is 21.  Fortunately for me, we all live in New Bern!  As a nurse I have had the opportunity to serve in many different capacities.  I enjoy Cardiopulmonary Rehab because we get to spend time getting to know our patients.  It is a wonderful opportunity to be their advocate, coach, cheerleader and educator.


Kelly’s contact information:

Christine Alford, Chair of the Membership Committee

I am the lead CEP for the cardiac rehab program at High Point Regional and I have been here since 2009.  I’m very passionate about cardiopulmonary rehab and I am thrilled to be a part of the NCCRA organization and all of the great things that we are making happen in the field.  I have been on the membership committee for the past 2 years and I think we have accomplished a lot and I’m excited to see what more we can do this year.  I am honored to be able to serve as the chair of this committee and am looking forward to working closely with all of you!

With that being said, please feel free to reach out to me with any ideas or concerns that we can address or any expectations that you may have for me or the rest of the membership committee.  Together, we can make this the best year yet!

Christine’s contact information:



Minutes from the Discipline Meetings – March 23,2018

Exercise Discipline Meeting   2018 NCCRA Exercise Discipline Meeting Minutes
If you have any questions please contact our Exercise Discipline chair:

Angela Lanier, MS ACSM-CEP
Clinical Exercise Physiologist, Cardiopulmonary Rehabilitation
Iredell Health System
557 Brookdale Drive
Statesville, N.C.  28677
704-878-4558 ext 3442
704-878-4951 (Fax)


Nutrition Discipline Meeting NCCRA Symposium Nutrition Discipline Minutes.docx 2018
If you have any question please contact our Nutrition Discipline chair:

Judith M. Hinderliter, MPH, RD, LDN, CPT
UNC Wellness Centers at Meadowmont
Registered Dietitian/Nutritionist Cardiac Rehabilitation
100 Sprunt Street
Chapel Hill, NC 27517
Co-director Wellness and Cardiovascular Nutrition subunit, SCAN dietetic practice group
Nutrition Discipline Chair, NC Cardiopulmonary Rehab. Assoc.
T 919.614.5704     F 984.974.2591


CMS documents updated 04-2018

LCD Cardiac Rehab March 2018

Pulmonary Rehab LCD Jan 2018

SET decision memo

Updated NCCRA bylaws


Other Educational Opportunities from our sister organizations

If you aren’t able to join us in Chapel Hill on March 22-23, 2018 – perhaps you can attend the symposiums around us.

South Carolina 2018 Cardio Brochure SCACVPR

Virginia  2018 VACVPR Conference Brochure

Proposed Readoption/Amendment of Certification of Cardiac Rehabilitation Programs – NC DHHS

Attached is the NC Department of Health and Human Services – Proposed Readoption/Amendment of Certification of Cardiac Rehabilitation Programs –  Rules – 10A NCAC 14F

The period of public comment is from December 15, 2017 – February 13, 2018 with a public hearing scheduled for January 2nd at 11:00am in Raleigh.


Rather than having each program respond with comments, we would suggest you forward suggestions/comments to Connie Paladenech –


Connie has agreed to “gather” all comments/suggestions to take to the public hearing on January 2nd.  In this way we can bring comments/suggestions from our affiliate membership of approximately 70+ programs.  


You may send your comments/suggestions individually, but we would ask that you cc them to Connie as well, so she can see what is being suggested.  

InterestedParties Readopt14F w Rule

CMS finalizes the cancellation of the Episode Payment Models and Cardiac Rehabilitation Incentive Payment Model

Today, the Centers for Medicare & Medicaid Services (CMS) finalized the cancellation of the mandatory hip fracture and cardiac bundled payment models that were to be operated by the CMS Innovation Center and implemented changes to the Comprehensive Care for Joint Replacement (CJR) Model. These changes will offer greater flexibility and choice for hospitals in providing care to Medicare patients.

“While CMS continues to believe that bundled payment models offer opportunities to improve quality and care coordination while lowering spending, we believe that focusing on developing different bundled payment models and engaging more providers is the best way to drive health system change while minimizing burden and maintaining access to care. We anticipate announcing new voluntary payment bundles soon,” said CMS Administrator Seema Verma.

In the final rule, CMS is reducing the number of mandatory geographic areas participating in CJR from 67 areas to 34 areas. As part of the agency’s ongoing commitment to addressing the unique needs of rural providers, CMS is also making participation voluntary for all low volume and rural hospitals participating in the model in all 67 geographic areas. This regulation also includes an Interim Final Rule with Comment Period, in which CMS is establishing and seeking comment on a final policy to provide flexibility in determining episode costs for participant hospitals located in areas impacted by extreme and uncontrollable circumstances, such as the major hurricanes of 2017.

CMS is also finalizing the cancelation of the hip fracture and cardiac bundled payment and incentive payment models – the Episode Payment Models and the Cardiac Rehabilitation Incentive Payment Model – that were scheduled to begin on January 1, 2018. Not pursuing these models gives CMS greater flexibility to design and test innovations that will improve quality and care coordination across the in-patient and post-acute care spectrum.

Moving forward, CMS expects to increase opportunities for providers to participate in voluntary initiatives rather than large mandatory bundled payment models. The changes in the final rule will help position the agency to engage in future voluntary efforts.

For a technical fact sheet on the changes in this final rule and interim final rule with comment period, please visit: