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The Impropriety of Bundling Outpatient Neurological Cognitive Rehabilitation with Residential Services - Care First Rehabilitation

The Impropriety of Bundling Outpatient Neurological Cognitive Rehabilitation with Residential Services

Troy, Michigan -At Care First Rehabilitation, we recognize the vital role that outpatient Neurological Cognitive Rehabilitation plays in the lives of individuals recovering from traumatic brain injuries, strokes, and other neurological conditions. However, there is a concerning trend where insurers and other entities attempt to bundle this specialized program into the overall residential care package, which is not only inappropriate but fundamentally flawed in its execution and reimbursement structure.

First, Neurological Cognitive Rehabilitation is a distinct clinical service that is billed separately under appropriate CPT codes (such as 97129 and 97130), is physician ordered and reflects the time-intensive, structured interventions provided by licensed therapists and rehabilitation professionals. These services go beyond routine residential care and require specialized expertise, tools, and techniques that are not part of daily living assistance provided in a residential setting.

Second, the program is delivered by non-residential personnel, meaning that rehabilitation specialists, cognitive therapists, and other medical professionals conduct the sessions as part of a structured, goal-oriented therapy plan. This differs significantly from the supportive care provided by direct care staff in residential settings, which focuses on assistance with activities of daily living (ADLs), behavioral oversight, personal care, and general supervision.

Finally, the success of Neurological Cognitive Rehabilitation is measured by clinical outcomes, including improvements in cognitive function, problem-solving, memory retention, and adaptive behaviors, all of which require formal evaluations, assessments, and progress tracking that align with industry standards for neurorehabilitation. These measurable benchmarks are separate from the daily observations of residential staff and must be professionally documented to justify continued therapy and insurance reimbursement.

Bundling these services into residential care misrepresents their purpose, execution, and billing process. Such an approach risks undermining the integrity of necessary rehabilitative treatment, jeopardizing the accuracy of reimbursement models, and ultimately failing the individuals who rely on structured cognitive rehabilitation for meaningful recovery. Care First Rehabilitation remains committed to advocating for the proper categorization, funding, and execution of these critical services.

For more information, please send an email to:  programs@carefirstrehabilitation.com.