Recent OIG audits of cardiac and pulmonary rehabilitation programs, in New Jersey, have provided some clarification on CMS rules and expectations of programs.  The key findings were related to the individual treatment plan (ITP).  We must be diligent in creating thorough ITPs for our patients, and making sure our medical directors or supervising physicians have direct contact with the patient prior to the initiation of services, and every 30 days thereafter.  In the past we had been told that some MACs acknowledged the challenge of being able to always obtain a signed ITP at exactly 30 days, and allowed flexibility.  However, the AACVPR recommends moving forward with a strict 30-day protocol.  The AACVPR Program Certification requirements are in line with the recommendations made by the OIG, therefore there are no changes in the requirements for the ITP for 2016.