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Is Your Practice Ready for a Medicare Audit? | Part Five

April 18, 2014/in Physical Therapy Billing, Physical Therapy Compliance, Physical Therapy practice management, Physical Therapy Software/by bestPT

In this fifth in our series of Blogs asking the question, “Is your practice ready for a Medicare audit?” we discuss Certifications and Re-certifications of the Plan of Care.

Medicare requires that a Plan of Care be prepared by a therapist or other qualified professional, who must sign and date the document. Additionally, the Plan of Care must be certified by a physician/NPP. The certification of the Plan of Care should occur as soon as possible after it is established or within 30 calendar days of the initial therapy treatment.

The Plan of Care should be certified as soon as it is established. Medicare may deny payment if the Plan of Care is not certified. Failure to obtain this required certification is among the most common findings in CERT audits performed by Medicare.

Re-certification of the Plan of Care also requires a physician or non-physician signature and date, and it should occur whenever there is a significant change in the plan or every 90 days from the initial plan of care certification.

A certification is different from an order or referral in that it must contain all required elements of a Plan of Care. Certification requires a dated physician/NPP signature on the therapy Plan of Care or some other document that indicates approval of the Plan of Care. Certifications/re-certifications should include the following elements:

The date from which the Plan of Care being sent for certification becomes effective (for initial certifications, the initial evaluation date will be assumed to be the start date of the certified Plan of Care.)
Diagnoses.
Long term treatment goals.
Type, amount, duration and frequency of therapy services.
Signature, date and professional identity of the therapist who established the Plan.
Dated physician/NPP signature indicating that the therapy service is or was in progress and the physician/NPP makes no record of disagreement with the Plan.

The interval length shall be determined by, “the patient’s needs, not to exceed 90 days” Certifications which include all the required Plan of Care elements will be considered valid for the longest duration in the plan (such as 3x/wk for 6 weeks which will be considered as a total of 18 treatments). If treatment continues past the longest duration specified, a recertification will be required.

Delayed Certification: Medicare provides for Delayed Certification when a physician/NPP makes a certification accompanied by a reason for the delay. This explanation should be kept as a part of the medical record. This allows needed therapy to be provided even if certification of the plan is delayed.

Note: Genco recently assisted a client in responding to a Medicare Audit where claims for any treatments provided in a period where there was no Certified Plan of Care were denied.

Medicare requires a legible signature of the person(s) who provided the service and certifying the Plan of Care. Signatures may be hand written or electronic. Electronic or hand written signatures that have been communicated through facsimile are also acceptable. Effective April 28, 2008, stamp signatures were no longer acceptable.

In our next Blog we will discuss documenting the care provided.

Genco Healthcare helps practices achieve and maintain a culture of compliance. We also assist Healthcare Attorneys in defending their clients who have been audited or subject to pre-payment review. Consequently, we have our finger on the pulse of precisely what Medicare’s expectations are when it comes to medical documentation. Contact us by email: David@Gencohealthcare.net.

Is Your Practice Ready for a Medicare Audit? | Part Four

March 25, 2014/in Physical Therapy Billing, Physical Therapy Compliance, Physical Therapy Documentation, Physical Therapy practice management, Physical Therapy Software/by bestPT

Physical Therapy Documentation_Audit-Checklist In this fourth in our series of Blogs asking the question “Is your practice ready for a Medicare audit?” we discuss The Plan of Care and the critical role we have seen it play in provider audits.

Therapy services shall be payable when the medical record and the information on the claim consistently and accurately report covered therapy services. Documentation must be legible, relevant and sufficient to justify the medical necessity of the services billed.

In our previous blogs we discussed that the medical record must paint a picture of the patient’s impairments and functional limitations requiring skilled intervention; and describe the prior functional level to assist in establishing the patient’s potential and prognosis. Based upon these findings and in keeping with established procedures and the clinical judgment of the therapist, the Plan of Care must:

Describe the skilled nature of the therapy treatment to be provided;
Justify that the type, frequency and duration of therapy being is medically necessary for the individual patient’s condition;

A separate Plan of Care is required for PT, OT and Speech if applicable. Medicare requires that the following items be included:

Diagnosis:

The diagnosis should be specific and as relevant to the problem being treated as possible. In many cases, both a medical diagnosis (obtained from the physician/NPP) and an impairment-based treatment diagnosis are relevant.Bill the most relevant diagnosis.

Note: This is where the challenge of implementing ICD 10 needs to get met head on. The therapist is required to use the “most relevant diagnosis and . . . the code that best relates to the reason for the treatment.” The specificity, laterality and granularity of the ICD 10 Code will reveal a great deal about the patient each time you bill. Care must be taken to assure that the code(s) selected are consistent with the information recorded throughout the patient’s medical record.

Long Term Goals (LTG’s): Based upon the findings in the Initial Evaluation, the patient’s prior level of function, and rehab potential the therapist determines the Long Term Goals for the patient. As a practical matter, goals should be reasonable, measurable and attainable within a reasonable period of time. Medicare specifies LTG’s should:

pertain to the functional impairment findings documented in the evaluation;
reflect the final level the patient is expected to achieve as a result of therapy in the current setting
be realistic, and should have a positive effect on the quality of the patient’s everyday functions;
be function-based and written in objective, measurable terms with a predicted date for achieving the goals.

Type of Treatment:

The type of treatment includes the type of therapy discipline operating under this Plan of Care (PT or OT) and should describe the types of treatment modalities, procedures or interventions to be provided.

Note: Genco was recently called in to assist a legal team prepare a response to a multimillion dollar Medicare Audit. A major issue was therapy services that were provided, billed and paid though were not included in the Plan of Care. These claims were denied by Medicare and contributed significantly to the overpayment.

Amount of Treatment:

Refers to the number of times in a day the type of treatment will be provided. Where not specified, one treatment session a day is assumed.

Treatment provided more than one session per day per discipline will require additional documentation to support this amount of therapy.

Frequency of Treatment:

Refers to the number of times in a week that the type of treatment is provided

Medicare expects that treatment more than two or three times a week to be a rare occurrence and that treatment frequency of greater than three times per week requires documentation to support this intensity.

Duration of Treatment:

Refers to the number of weeks, or the number of treatment sessions, for this Plan of Care. Clinicians could also estimate the duration of the entire episode of care in this setting.

In our next Blog we will discuss Certifications and Re-certifications of the Plan of Care.

Genco Healthcare helps practices achieve and maintain a culture of compliance. We also assist Healthcare Attorneys in defending their clients who have been audited or subject to pre payment review. Consequently, we have our finger on the pulse of precisely what Medicare’s expectations are when it comes to medical documentation. Contact us by email: David@Gencohealthcare.net.

Generating a Steady Stream of Referrals Is Not That Complex

March 20, 2014/in Physical Therapy Billing, Physical Therapy patient relationship management, Physical Therapy practice management, Physical Therapy Software/by bestPT

By Erika Trimble

Yes, to generate a steady stream of referrals and grow your practice you need to market. But marketing need not be complex. In fact the easiest and most affordable marketing strategy open to you is to build your client referrals.

This is a case of your clients doing your marketing for you. Consider this fact: people who refers once can refer many more times. They will refer many more times when you nurture your relationships with them. Nurturing your relationships means that you ensure your clients are satisfied, come back to you over and over again. These satisfied clients will always be willing to talk about you to others, and tell them about the great experience they had with you. This is what we call very powerful marketing because such testimonials are proof of the value of your services.

It is important to remember that at the very core of marketing your business is building relationships. Relationships bring you new clients, they influence your reputation, they spread your ideas, and much more.

Bear in mind that it’s not just about quantity of relationships (though that helps), it’s also about quality. Nurturing and cultivating good relationships is what results in having more clients, with less work.

If you’re tired of worrying about how many clients will walk in the door next week, and whether it will be enough to keep your practice afloat, then it is time for you to stop leaving referrals to chance!

Getting your current customers to stick with you is key to your practice’s growth and long-term profitability. When they stick with you, you have every chance of generating even more referrals from them.

In fact, for every 1 percent increase you achieve in customer retention, there’s a 7 percent increase in profitability. That’s huge!

When you lose a customer, it is absolutely worth your time and effort to get them back. Why?

Learning why customers leave your business is the first step in managing your referrals. Once you know the reasons people aren’t returning to you, you can prevent this from happening again.

I know some of you may feel uncertain and overwhelmed when I mention the idea of building referral relationships or even getting referral sources.

Just know there are people and resources to help you. Contact us at coach@erikatrimble.com to learn how we can help you.

http://www.prosperousphysicaltherapy.com/

Empathy-O & W Enterprises | Practice of the Month

March 19, 2014/in Physical Therapy Billing, Physical Therapy practice management, Physical Therapy Software/by Tom Jorno

Striving To Provide “Best in Class” Therapy

When Brad Adams began his physical therapy after shoulder surgery, he wasn’t sure he would ever fully recover. He described the pain as “terrible,” and felt that his progress was extremely slow.

On the other hand, Adams describes his first appointment with Empathy-O&W Enterprises in Bassett, Va. — for a process called “dry needling” — as “amazing.” Within a day, he had “considerable pain relief and increased mobility.”

Empathy-O&W prides itself on being able to provide unique and seamless rehab solutions for companies that have staffing shortages large and small. The company incorporates state of the art tools for our clients and therapists including electronic documentation, integrated billing, compliance software controls and systems. Empathy embraces change management and strives to stay ahead of the curve by developing new and innovative ways to improve therapy delivery.

“Throughout the rest of my PT and dry needling,” says Adams, “I have reached a level of recovery that is remarkable. I was “˜released’ six months after surgery when therapy could have taken up to a year.”

Empathy was founded on six key points of value: Experience, Leadership, Compliance, Profitability, Dependability, and Teamwork. It is their mission to utilize each key value throughout the organization to guide corporate growth and to promote the essential goals of: providing “best in class” therapy, delivering excellence in customer service, and achieving industry leading employee retention. The organization intends to provide patients and partner facilities with the best therapy experience””by providing dependable and teamwork-driven clinicians who deliver organized, structured, and individualized treatments at the highest level of compliance and integrity.

“We wanted to create a company that we would like to work for ourselves; a company that truly embraced the distinct field of therapy, and the collaborative model of patient recovery, as well as a company that is dedicated to the facilities we serve,” says Mark Okafor, president. “We act as a true extension of the healthcare team.”

Medicare Cap and Payment Reductions for 2014

December 31, 2013/1 Comment/in Physical Therapy Billing, Physical Therapy Documentation, Physical Therapy Software/by bestPT

MEDICARE THERAPY CAP FOR 2014

On December 26, 2013, President Obama signed into law the Pathway for SGR Reform Act of 2013. This new law prevents a scheduled payment reduction for physicians and other practitioners who treat Medicare patients from taking effect on January 1, 2014.

The new law also extends several provisions of the Middle Class Tax Relief and Job Creation Act of 2012 (Job Creation Act) as well as provisions of the Affordable Care Act. Specifically, the following Medicare fee-for-service policies have been extended.

Section 1103 -Extension Related to Payments for Medicare Outpatient Therapy Services -Section 1103 extends the exceptions process for outpatient therapy caps through March 31, 2014.

Providers of outpatient therapy services are required to submit the KX modifier on their therapy claims, when an exception to the cap is requested for medically necessary services furnished through March 31, 2014.

In addition, the new law extends the application of the cap and threshold to therapy services furnished in a hospital outpatient department (OPD).

All Medicare beneficiaries began a new cap for outpatient therapy services received on January 1, 2014. For physical therapy and speech language pathology services combined, the 2014 limit for a beneficiary on incurred expenses is $1,920. There is a separate cap for occupational therapy services which is $1,920 for 2014. Deductible and coinsurance amounts applied to therapy services count toward the amount accrued before a cap is reached, and also apply for services above the cap where the KX modifier is used.

Section 1103 also extends the mandate that Medicare perform manual medical review of therapy services furnished January 1, 2014 through March 31, 2014, for which an exception was requested when the beneficiary has reached a dollar aggregate threshold amount of $3,700 for therapy services, including OPD therapy services, for a year. There are two separate $3,700 aggregate annual thresholds: (1) physical therapy and speech-language pathology services, and (2) occupational therapy services.

Please note that these provisions do not reflect all of the Medicare provisions in the new law, and more information about other provisions will be forthcoming. The Genco team will continue to monitor this situation and share this information with our clients as it becomes available.

Genco Healthcare helps practices achieve and maintain a culture of compliance. We also assist Healthcare Attorneys in defending their clients who have been audited or subject to pre payment review. Consequently, we have our finger on the pulse of precisely what Medicare’s expectations are when it comes to medical documentation.

Physical Therapy Billing | Client Testimonial by Shecanna Seeley, DPT

March 27, 2013/in Client Testimonials/by Eldad De-Medonsa, PhD

Client Testimonial by Shecanna Seeley, DPT

Patients come to Indiana State University because they expect more. In fact the tag-line at ISU is “More. From Day One.” That’s why Shecanna Seeley, Director of Rehab Services at ISU chose bestPT. In her words:

â€œOur experience with bestPT has been very positive.

The ability to obtain instant, real-time data regarding patient account information via the internet-based billing software has been especially helpful. We are able to focus on patient care knowing that billing and collections are being handled properly. The bestPT staff members are knowledgeable, helpful and quick to respond.

We would recommend bestPT to other providers without hesitation.â€

Shecanna Seeley, DPT
Director of Rehabilitation Services
Sycamore Center for Wellness and Applied Medicine
Indiana State Unitversity
College of Nursing, Health, and Human Services

Physical Therapy Billing | Welcome to the BestPT team!

February 20, 2013/in Physical Therapy Billing, Physical Therapy Billing Network Members, Physical Therapy Software/by Eldad De-Medonsa, PhD

Welcome New Members to the bestPT Team!

Ten New members joined bestPT in August 2014.

Each of our new members benefit from and contributes to our network strength. A billing problem solved for one practice will then be automatically applied to all of our clients.

Let’s welcome bestPT newest members!

Ryan and Jordan Thompson of Thompson Physical Therapy Fresno, CA
Kalyn Altherr and Josh of ISU Physical Therapy & Sports Rehabilitation Clinic Haute, IN
Lydia Konshur of Kalispell Rehab. Kalispell, MT
Melissa Ruiz of Equilibrium Balance Performance Center Ventura, CA
Emily Burton of Back In Motion Therapy Washington, IN

Top 10 Physical Therapy And Rehabilitation Golden Opportunities!

February 14, 2013/in Physical Therapy Billing, Physical Therapy practice management, Physical Therapy Software/by Tom Jorno

Physical Therapists and private practice rehabilitation owners continuously struggle with ways of marketing their services to the community where they provide services. We advertise, develop web sites and create elaborate marketing materials. In this marketing campaign, we often overlook our most valuable resources; ourselves and our staff.

Every day, in every thing we do, we are presented with opportunities to market our Physical Therapy service, skills and knowledge. Simple opportunities present themselves when attending local sporting events, going to a doctor visit with your child, or even offering words of advice to a local community group. When presented with these opportunities, it is important to remember to take a moment to make a connection with the other person and use the strategies listed below to make a lasting, positive impression. Making a good first impression is a singular opportunity! An opportunity which can change the profitability and success of your Physical Therapy and Rehabilitation practice.

TOP 10 DAILY GOLDEN OPPORTUNITIES

1. Provide written schedule of appointments-A written schedule of appointments will improve the customers’ attendance by decreasing opportunities for cancellations due to not remembering the date/time of the appointment, location or phone number to call and reschedule.

2. Discuss what to strive for/goals-establishing goals with the client in cooperation with the Physical Therapist clarifies what therapy can and can not do for the client. A clear level of communication and expectations are established.

3. Provide written information-Home exercise programs, internet and written references provide ongoing learning at the client’s own pace and contributes to the client’s increased level of responsibility for their own success.

4. Start and end your session on time-Respect your client’s time and they will respect your time in return.

5. Send reports in a timely manner-Documenting treatment and delivering this information to the team of care providers effectively and efficiently helps to manage the timeliness of treatment protocols.

6. Discuss other therapies and their benefits-An informed client who makes their own choices will participate in the therapy plan of care with an increased level of commitment and success.

7. Serve as a referral source for family/client-The Physical Therapist is the coach. We must help the client access and successfully utilize the resources in their community in an appropriate manner to compliment, support and eventually be a replacement for the physical therapy program once they have achieved their rehabilitation goals.

8. Look for opportunities to promote yourself, coworkers and services-You are your own greatest advocate! Share conferences you have recently attended, materials you have read, and provide access to information your coworkers and team-mates are learning!

9. Provide business cards to contacts-Business cards do more than share vital statistics about credentials and contact information. They are a tangible reminders of your interaction which represent you and your company.

10. Send thank you note in appreciation for the visit-Common courtesy and appreciation are hallmarks in treating our clients with respect.

Physical Therapists and Rehabilitation practice owners can use the Top 10 Daily Golden Opportunities to market their services and skills. They take very little time or financial resources to implement. If you consistently capitalize on everyday opportunities, you may find the “small” impressions you make today will take root and grow into big returns in the future.

Gerilyn M. Gault, BSPT, is co-owner of the rehabilitation company http://www.gandetherapies.com and Account Specialist for bestPT. Gerilyn is an advanced neurological clinician with years of experience in professional staffing, private practice, contract and fiscal management.

Fair OT Coverage Under Medicare: LCDs FAQ

February 6, 2013/in Physical Therapy Billing, Physical Therapy practice management, Physical Therapy Software/by Tom Jorno

How to Advocate for Fair OT Coverage Under Medicare: LCDs FAQ

Regional Medicare Local Coverage Determinations (LCDs) are undergoing some changes. Under the Medicare Program, Medicare contracts with regional corporate entities that process and pay claims for services provided in their regions which may range from one state to multiple states to parts of states. These entities, usually insurance companies, have in the past been called “carriers” or “fiscal intermediaries” but due to recent legislative changes are moving to be called Medicare Administrative Contractors (MACs). This article presents key issues about LCD changes already underway, and opportunities for advocacy.

What is an LCD?

LCDs are coverage and payment policies that have been used by current carriers and fiscal intermediaries but will also be used in the regions covered by the new MACs to interpret national Medicare policy issued by the Centers for Medicare and Medicaid Services (CMS). LCD coverage policies may be based on discipline (e.g., an LCD might be titled “occupational therapy” or “physical medicine and rehabilitation”) or type of service (e.g., wound care services; dysphagia services and so forth).

What is Changing?

The Medicare Prescription Drug, Improvement and Modernization Act of 2003 (MMA) enabled CMS to make significant changes to the Medicare fee-for-service program’s administrative structure. The key feature is that the MACs will gradually be identified over the next several years to replace the old carriers and fiscal intermediaries. Under the law’s provision for Medicare Contracting Reform, CMS will integrate the administration of Medicare Parts A and B into one regional entity-a MAC. All Part A and B fee-for-service claims will be processed through these new entities. As part of the reform, CMS is conducting open competitions to replace contractors but it will take time. Affected regions are being phased in from 2005-2011.

What is Affecting Occupational Therapy Now?

The MACs are currently being selected and as part of the reform process, LCDs are under review. As MAC contracts are awarded to local Medicare contractors, these contractors are re-examining existing LCDs that govern Physical Medicine and Rehabilitation policies in their coverage region and are consolidating and revising the LCDs, typically through a stakeholder notice and comment process.

What Should Occupational Therapy Practitioners Do About the Changes?

The changing contracting process is one reason for the recent explosion of open LCDs and requests from new MACs for therapists to provide comments on an LCD. LCDs are required to allow for some public comment. It is imperative that practitioners follow the changes in the process and entities that affect their Medicare billing by watching the Web sites of current and new entities.

While some LCDs recognize the full scope of occupational therapy practice, LCDs frequently present inappropriate or erroneous information on the occupational therapy scope of practice and that of other therapy disciplines. Further, these inappropriate LCDs may lead to AOTA members receiving widespread Medicare denials of claims for services that occupational therapists are educated and licensed to provide. There have always been efforts made by therapists and sometimes state associations to affect and change LCDs; AOTA also weighs in with comments on many LCDs. With the many changes now happening, it is important that all in the field watch what entities are doing to protect occupational therapy practice, payment, and scope of practice. The best source of information is the Web site of your current fiscal intermediary or contractor. Changes to MACs will be posted there.

What Materials Are Available to Help Me Be an Advocate on LCDs?

AOTA wants to provide members with the following tools and resources to respond to requests for comments on LCDs:

LCD Advocacy Packet: This packet provides the materials and resources necessary to enable state associations and individual practitioners to monitor and advocate for OT services under Medicare, critical fact sheets, AOTA official documents, and sample LCD comment letters are included.

Medicare Benefit Policy Manual – Presents frequently used citations. (See Chapter 15)

Chapter / Section / Subsection / Title
	15/220 – Coverage of Outpatient Rehabilitation Therapy Services (Physical Therapy, Occupational Therapy, and Speech-Language Pathology Services) Under Medical Insurance
	15/220.2 – Reasonable and Necessary Outpatient Rehabilitation Therapy Services
	15/220.3 – Documentation Requirements for Therapy Services
	15/230 – Practice of Physical Therapy, Occupational Therapy, and Speech-Language Pathology

Article from www. AOTA.org

Physical Therapy Software is used by Mike Walsh, PT.

Physical Therapy Software | bestPT gets me paid – Michael Walsh, PT

February 5, 2013/in Client Testimonials, Physical Therapy Billing, Physical Therapy Software/by bestPT

Billing Dynamix and bestPT gets Michael Walsh, PT “PAID” at his Physical Therapy Practice

How? By using the physical therapy software that was developed with physical therapy practices in mind. The documentation can be completed in a matter of clicks and the claim scrubbers ensure quick payment from the notoriously slow Payers.