Medicare only wants to pay for physical therapy that prevents a decline in function and subsequent loss of independent living.
For example, physical therapy that keeps a Medicare beneficiary at home and prevents a transfer to a nursing home is valuable to Medicare because the level of care and skilled services in a nursing home creates higher costs for the Medicare system and for society in general. Valuable physical therapy can prevent this loss of independence
Medicare wants to pay for valuable physical therapy.
Medicare will buy as much valuable physical therapy as you are selling.
Physical Therapy is a “Black Hole”
Physical therapist Alfonso Amato says in IMPACT magazine (Vol.3, Issue 10) the following:
“…payors describe outpatient rehabilitation as a ‘black hole’: they don’t know what they are paying for, don’t know the benefit of the service, and don’t know when the patient has reached maximum benefit”
Currently, the measure of the value of your therapy is the detailed chart documentation that describes the change in functional limitations and the change in physical impairments.
Chart documentation is what auditors look at to determine if you should return your fee, or not.
Medicare does not want to pay for physical therapy that is not valuable.
Is your physical therapy valuable?
Your chart documentation will tell you.
Audit Yourself
Can you open your chart, read your note and determine from one or two entries why and what the patient is doing in physical therapy? Is the patient improving functional abilities? Are their impairments getting better?
Does each entry reflect the skill of a physical therapist or physical therapist assistant? Is the skilled service obvious?
Show the Medicare auditor that your chart is full of hard data, critical thinking assessments, skilled physical therapy examples and diagnosis-driven decisions.
Write them down.
For example, use the language from the Benefits Policy Manual (Transmittal 63) to describe improvements in functional abilities:
“Objective data that demonstrates improved functional abilities is the OPTIMAL score decreased from 2.5 to 1.5 in 4 weeks, as expected”
Put that statement in your discharge note.
Make it easy for the Medicare auditor to decide to move on to the next chart.
Low-hanging Fruit
Don’t be the ‘low-hanging fruit’ that the auditors love to pick on.
Make your chart documentation difficult to disprove.
Make the auditor work hard to find a fault in your critical thinking.
Build a strong case for the physical therapy that your patient needs.
Argue for the patient, in writing, with numbers, measurements and functional scores that demonstrate the following:
* Skilled physical therapy services each and every session.
* Medical necessity for physical therapy services (only needs to be noted in the plan of care).
* Expect significant improvement in a predictable timeframe.
Imagine the following scenario:
You are an auditor paid to find fault with physical therapy charts. You find that most physical therapy entries are handwritten, overly brief and directed towards patient symptoms and specific tasks, like exercise.
Your income is based on finding charts that do not demonstrate the above criteria.
Yours is a thankless job.
Now you’ve come across a chart that is full of detailed impairment measurements, functional scores and sharp assessments that show critical thinking by the physical therapist.
The Treatment Encounter Notes are mainly numbers that show bilateral measurements and are compared against initial values. Goals are referenced weekly. Interventions are described daily.
Progress Notes are sent every calendar month for re-certification of the Plan of Care and include statements of medical necessity and justify any exceptions to Medicare caps on spending.
Discharge Notes clearly state who got better, by how much and who did not get better. The medical necessity for the non-responders is clearly stated in each discharge note.
You realize this chart will be a lot of work.
You can quickly scan this chart for any obvious omissions but your chances of a significant recovery are better if you move on to a different chart (and a different therapist).
Who Knows Who
In some cases, Medicare physical therapy auditors are physical therapists. They know what good physical therapy looks like.
To minimize your chances of a significant, unfavorable post-payment audit you should try to provide the best physical therapy you possibly can provide.
Provide valuable physical therapy.
Write it down.
Valuable, written physical therapy will survive a Medicare audit.
Valuable physical therapy is better for your patients.
