Medicare Blog

how do we make physical therapists comply with medicare rules

by Maurice Halvorson Published 2 years ago Updated 1 year ago

PTs must develop a plan of care (POC) for every Medicare patient, and a physician or nonphysician practitioner (NPP) must certify that POC within 30 days of the initial therapy visit. That being said, Medicare does not require the patient to actually visit the certifying physician or NPP, although that physician or NPP may require a visit.

Full Answer

What are the Medicare rules for physical therapy?

Medicare rules for physical therapy are based on the original Medicare. Coverage rules and limits may vary if you have a Medicare Advantage plan with an HMO or PPO; however, your coverage must meet or exceed coverage under original Medicare plans.

Can a physical therapist establish a plan of care?

CMS says either a physician/NPP or physical therapist can establish the POC but if the therapist does it then physician/NPP must approve of the plan. That’s where the signing off on the plan of care by the physician/NPP affirms that the patient is under their care and they agree with the plan.

Do Medicare Advantage plans cover physical therapy?

Coverage rules and limits may vary if you have a Medicare Advantage plan with an HMO or PPO; however, your coverage must meet or exceed coverage under original Medicare plans. (see Reference 1, 3) Physical therapy may be provided by licensed physical therapists or qualified doctors and nurses.

Are You complying with Medicare compliance requirements?

While there are special compliance requirements with Medicare patients, the reality is you should treat them like anyone else. Medicare expects you to evaluate the patient, determine their rehabilitation needs and address those needs.

What is compliance in physical therapy?

Know the rules. Follow them. The term "compliance" encompasses a range of issues, from fraud and abuse to following requirements of the Americans with Disabilities Act, Medicare, Medicaid, and other entities.

Can physical therapists bill Medicare?

Physical therapy billing guidelines for Medicare and Medicaid services include a section about how much time you must spend with a patient for it to be “bill-worthy.” Medicare physical therapy billing works in increments of 15.

Can PTs opt out of Medicare?

Unlike many other types of practitioners, physical therapists cannot “opt out” of Medicare. In fact, the closest thing PTs have to “opting out” is simply not having any type of relationship with Medicare.

How often does a PT have to see a Medicare patient?

The PT must recertify the POC “within 90 calendar days from the date of the initial treatment,” or if the patient's condition evolves in such a way that the therapist must revise long-term goals—whichever occurs first.

How does Medicare reimburse physical therapy?

However, in 2018, the therapy cap was removed. Original Medicare covers outpatient therapy at 80% of the Medicare-approved amount. When you receive services from a participating provider, you pay a 20% coinsurance after you meet your Part B deductible ($233 in 2022).

What is the AMA 8 minute rule?

The AMA uses similar guidelines as Medicare in that 1 unit equals 8 minutes. Where the AMA differs is that there is no cumulative restriction or adding of minutes, even for time-based codes. Every code will be allowed 1 unit for each 8 minutes performed.

How do I refuse Medicare Part B?

Call the Social Security Administration at 800-772-1213 and ask if you can decline Part B without any penalties. Write down who you spoke with, when you spoke to them and what they said. should write a letter to the Social Security Administration declining Part B. Keep a copy of the letter for yourself.

How do I not use Medicare?

If you keep working beyond age 65, you may have health insurance through your employer or have purchased a plan outside of Medicare. In this case, you may choose to refuse Medicare coverage. However, delaying enrollment can add extra costs or penalties down the road.

Why do doctors opt out of Medicare?

There are several reasons doctors opt out of Medicare. The biggest are less stress, less risk of regulation and litigation trouble, more time with patients, more free time for themselves, greater efficiency, and ultimately, higher take home pay.

What setting does Medicare require that the physical therapist must be in the room when the physical therapist assistant provides a service?

private practice settingAnswer: Under normal circumstances, the Centers for Medicare and Medicaid Services (CMS) requires the PT or OT to provide direct supervision to the PTA and OTA, respectively, when they are treating a Medicare beneficiary for outpatient therapy services in a private practice setting.

What are the Documentation guidelines for medical services?

Medical records should be complete, legible, and include the following information.Reason for encounter, relevant history, findings, test results and service.Assessment and impression of diagnosis.Plan of care with date and legible identity of observer.More items...•

When should a patient be discharged from physical therapy?

The physical therapist discontinues intervention when the patient/client is unable to continue to progress toward goals or when the physical therapist determines that the patient/client will no longer benefit from physical therapy.

What is part B in physical therapy?

Physical therapy. Part B covers certain doctors' services, outpatient care, medical supplies, and preventive services. Health care services or supplies needed to diagnose or treat an illness, injury, condition, disease, or its symptoms and that meet accepted standards of medicine. outpatient physical therapy.

What is Medicare approved amount?

Medicare-Approved Amount. In Original Medicare, this is the amount a doctor or supplier that accepts assignment can be paid. It may be less than the actual amount a doctor or supplier charges. Medicare pays part of this amount and you’re responsible for the difference. , and the Part B deductible applies.

How to enroll a physical therapist in Medicare?

For a physical therapist to enroll as a Medicare Part B provider the following steps must be followed: 1.) You must create your Medicare I&A account login. 2.) You must apply for a personal NPI (Type 1) 3.) You must apply for an organizational NPI (Type 2) for your business. 4.)

What is Medicare 855b?

The CMS 855i is the individual enrollment for a sole proprietor or a sole owner. The CMS 855b is the enrollment application for a clinic or group practice. The 855r is the reassignment of benefits. YouTube. Learn Medicare Billing for PT, OT, SLP. 2.64K subscribers.

Do physical therapists have to enroll in Medicare?

Does a Physical Therapist Need To Enroll In Each Medicare Advantage Plan? You are not automatically enrolled as a Medicare Part C ‘aka’ Medicare Advantage plan provider simply because you are enrolled in Medicare part B. If you would like to become an in network provider with Medicare Advantage plans you must enroll individually in each plan.

Why is Physical Therapy Valuable?

According to the American Physical Therapy Association (APTA), physical therapy can help you regain or maintain your ability to move and function after injury or illness. Physical therapy can also help you manage your pain or overcome a disability.

Does Medicare Cover Physical Therapy?

Medicare covers physical therapy as a skilled service. Whether you receive physical therapy (PT) at home, in a facility or hospital, or a therapist’s office, the following conditions must be met:

What Parts of Medicare Cover Physical Therapy?

Part A (hospital insurance) covers physical therapy as an inpatient service in a hospital or skilled nursing facility (SNF) if it’s a Medicare-covered stay, or as part of your home health care benefit.

Does Medicare Cover In-home Physical Therapy?

Medicare Part A covers in-home physical therapy as a home health benefit under the following conditions:

What Are the Medicare Caps for Physical Therapy Coverage?

Medicare no longer caps medically necessary physical therapy coverage. For outpatient therapy in 2021, if you exceed $2,150 with physical therapy and speech-language pathology services combined, your therapy provider must add a modifier to their billing to show Medicare that you continue to need and benefit from therapy.

Can a therapist cosign a Medicare claim?

Medicare won’t allow credentialed therapists to cosign claims for non-credentialed employees, so the uncredentialed therapist should reassign his or her individual Provider Transaction Access Number (PTAN) to the practice, and that practice should hold all the claims until he or she is fully credentialed.

Can a therapist cosign a note?

Many non-Medicare insurance companies allow a credentialed therapist to cosign a non-credentialed therapist’s note if the cosigning therapist supervises the treatment. Similar to the rules governing billing for PTA services, the credentialed therapist must provide direct onsite supervision and be immediately available to intervene if necessary. According to WebPT founder and COO Heidi Jannenga, PT, MPT, ATC/L, cosigning should be used as a temporary fix only. It’s definitely not appropriate as a long-term solution. Jannenga also recommends that all practices check with their specific insurance companies to verify the rules governing cosigning and credentialing, as many requirements vary.

When do you need to submit a progress note to Medicare?

The 10-visit rule replaced the 30-day rule, meaning therapists must submit a progress note on or before the patient’s 10th visit in order to comply with this regulation.

When does a therapist complete a progress note?

The therapist completes a progress note on August 31, which marks the patient’s 10th visit. The patient subsequently misses his or her next visit during the first week of September due to being ill; attends another visit; and then misses two additional visits due to being on vacation the following week.

What is POC modification?

POC modification is necessary when a patient’s status changes. The therapist must then obtain physician signature for the updated POC. So, what constitutes a status change? Typically, there is a disruption to care (e.g., the patient is hospitalized for a medical issue unrelated to the current condition for which he or she is being treated) or a new issue or event arises that you feel requires prompt attention and treatment (e.g., the patient is receiving treatment for a lumbar diagnosis and is now complaining of shoulder pain, or the patient was receiving treatment for knee pain when he or she sustained a fall, and he or she now presents with an ankle fracture that does not require surgical intervention).

What is Medicare Part B?

Medicare Part B is the component of Medicare that allows for the delivery of outpatient services. The general guidelines associated with billing for these services (including physical therapy, occupational therapy, and speech-language pathology) include establishing the plan of care (POC), certifying the plan of care by obtaining the signature of the referring physician or qualified NPP (non-physician practitioner), submitting progress notes at specified intervals, recertifying the POC after the expiration date if services are to be continued, including measurable short- and long-term functional goals, and completing functional limitation reporting (a.k.a. G-code reporting).

How many visits to a therapist in August?

The patient attended therapy regularly throughout August, completing a total of 10 visits by the end of the month. The patient is progressing well, and the therapist recommends that he or she continue for three more weeks, in accordance with the initial plan of care.

Does Medicare have a functional reporting system?

Medicare’s functional reporting system has been in place for a number of years, but many therapists are still unsure of how to correctly report G-codes. CMS introduced G-codes so providers could functionally categorize patients by indicating their abilities based on a percentage.

What happens if you don't comply with Medicare?

If, in the course of the audit, they find you do not have the Certifications/Re-certifications, if appropriate, included in the chart they can deem your care for that patient as not meeting the medical necessity or the requirement to be under a physician’s care. In that case Medicare can decide that all the care for these patients should not have been carried out and can ask for all payments plus interest and a penalty to be returned to them. This can come to a significant amount of money, especially if it occurs in a number of patient’s charts.

How long can a Medicare plan of care be certified?

The maximum length of time any certification period used to be 30 days, however now it can run up to 90 days.

How to get a POC?

A POC being sent for certification must contain ALL of the following elements to meet the requirements: 1 The date the plan of care being sent for certification becomes effective (the initial evaluation date is acceptable) 2 Diagnoses 3 Long term treatment goals 4 Type, amount, duration and frequency of therapy services 5 Signature, date and professional identity of the therapist who established the plan 6 Dated physician/NPP signature indicating either agreement with the plan or any desired changes.

What are the requirements for a POC?

A POC being sent for certification must contain ALL of the following elements to meet the requirements: The date the plan of care being sent for certification becomes effective (the initial evaluation date is acceptable) Diagnoses. Long term treatment goals. Type, amount, duration and frequency of therapy services.

How long is a Medicare certification?

The length of the certification period is the duration of treatment, e.g. 2x/week for 8 weeks. In this example the end date of the certification period is 8 weeks, to the day, from the initial evaluation date. In 2008 Medicare changed the requirement for the maximum duration of each plan of care. The maximum length of time any certification period ...

Can a physical therapist establish a POC?

CMS says either a physician/NPP or physical therapist can establish the POC but if the therapist does it then physician/NPP must approve of the plan. That’s where the signing off on the plan of care by the physician/NPP affirms that the patient is under their care and they agree with the plan.

Can you claim all your patients require the maximum time allowed?

Claiming all your patients require the maximum time allowed may trigger an audit of your documentation. CMS recommends you set the duration for your certifications at your best estimate of the length of time it will take your patient to achieve their goals.

How long does it take for a physical therapist to be certified by Medicare?

Before beginning treatment, Medicare requires your doctor or physical therapist to create a plan of care that includes your diagnosis, treatment goals and a description of the type and amount of treatment services that will be provided. Physical therapists must document your treatments and any changes o the plan of care. (see Reference 2, section 220.1.2 B) The plan of care must be approved and signed by your physician or non-physician practitioner within 30 days of you initial treatment to be considered certified. Plans must be recertified every 90 days or whenever the plan is significantly changed. If the plan of care is not certified, Medicare may deny coverage of treatments. (see Reference 2, section 220.1.3)

What are the requirements for a physical therapist?

A physical therapist must be meet all the state requirements to practice physical therapy, pass a national exam and have graduated from a physical therapy program approved by the Commission on Accreditation in ...

What is a plan of care for Medicare?

Before beginning treatment, Medicare requires your doctor or physical therapist to create a plan of care that includes your diagnosis, treatment goals and a description of the type and amount of treatment services that will be provided.

How often do you need to report progress on Medicare?

An evaluation of the patient is required and may be included with the plan of care. Treatment notes for each appointment, progress reports every 10 days or less and discharge notes after each outpatient treatment is finished must be maintained and submitted to Medicare when requested.

Who provides physical therapy?

Physical therapy may be provided by licensed physical therapists or qualified doctors and nurses. In addition to physical therapy offices, you may also see physical therapy treatments in some medical offices, rehabilitation agencies, outpatient departments at your hospital, comprehensive outpatient rehabilitation facilities or skilled nursing ...

Does Medicare cover physical therapy?

Medicare rules for physical therapy are based on the original Medicare. Coverage rules and limits may vary if you have a Medicare Advantage plan with an HMO or PPO; however, your coverage must meet or exceed coverage under original Medicare plans. (see Reference 1, 3)

Why doesn't Medicare cover PTs?

For PTs, such exclusions typically fall into the “prevention,” “wellness,” or “fitness” categories.

Can you collect cash from Medicare?

Thus, you cannot collect cash payment for such services directly from a patient—even if the patient wants to pay cash. With this type of relationship, you can still collect cash payment for services Medicare will not cover, either due to statutory exclusion (i.e., services that Medicare never covers) or lack of medical necessity.

Do you need an ABN for a non-covered therapy?

If the patient would like to pay out-of-pocket for non-covered therapy services, no ABN is required. However, you do have the option of issuing a voluntary ABN, or a similar consent form, as a courtesy to the patient.

Does Medicare require prior authorization?

In fact, while Medicare does not require patients to obtain prior authorization before receiving therapy services, some MA plans do. So, to ensure you're always in compliance, check with the specific MA plan provider—as well as your state practice act—before providing services.".

Is therapy considered medically necessary?

Furthermore, therapy treatment is considered medically necessary “ if the type, amount, and duration of services outlined in the plan of care increase the likelihood of meeting one or more of these stated goals: to improve function, minimize loss of function, or decrease risk of injury and disease.”.

Can you treat Medicare patients on a cash-pay basis?

You can, however, treat Medicare patients on a cash-pay basis for non-covered services.". So, if the services you're referring to are Medicare-covered, then you would not be able to provide them to a Medicare patient if you didn't have a relationship with Medicare.

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