"Physical therapy is not a subspecialty of the medical profession and physical therapists are not medical doctors; we are a separate profession that provides a unique service that physicians are unable and untrained to provide."

Letter to the AMA from the APTA, Dec 2009

Sunday, March 1, 2009

Is Medicare compliance related to clinical competence?

Bulletproof Decision Making started out as my own professional exploration of Medicare chart compliance for my private practice physical therapy clinic.

(note: you can sign up for Bulletproof at the bottom of this page)

I wanted to make a better compliance plan for my Medicare charts and notes.

My starting assumption was that good clinical documentation is completely related to competent clinical decision-making.

It is not.

Good clinical documentation today (2009) is all about dotting your 'i' s and crossing your 't' s.

What I learned

In early 2009, I paid a Medicare auditor $1,000 to come in and examine my charts and comment upon my compliance program. As you might expect, the auditor was able to find many 'deficiencies' in my charts.

I realized then that, to be helpful to other private practice therapists, Bulletproof needed to be about physical therapists' decisions driving treatment, documentation and compliance.

Why do physical therapists' decisions matter to Medicare?

Within a few short years, physical therapists may track their patient outcomes using remote data-gathering technology such as e-mail, web-based forms and CAT testing.

Patients could enter their own data.

This should reduce the 'information asymmetry' that has led some insurers to refer to physical therapy as a 'black hole' into which money disappears.

Currently, 52% of physical therapists do not use outcome measures which means that payers have no information showing if their beneficiaries got better, or not.

Electronic, standardized outcome measures will provide information on patient functional progress as well as initial and ongoing medical necessity for physical therapy.

Who are the Doctors?

Expansion of physical therapists' ability to serve as front-line health care providers means that the complexity of physical therapists decisions will determine the extent and intensity to which those services can be billed.

Physical therapists will bill like physicians.

Currently, physicians use Evaluation and Management codes (E/M) , that one day I hope physical therapists will use.

Payment to physicians is based on the following:
  • an extended patient history
  • detailed, multi-systems exam
  • number of diagnoses
  • complexity of decision-making
How do compliance and competence relate to each other?

Bulletproof is a resource that prepares physical therapists for the day when our decisions drive practice: when the frequency, intensity and need for physical therapy are derived from our physical therapy diagnosis.

The duration of physical therapy will be derived from the physical therapy prognosis.

I eagerly await the day when a Medicare audit of my charts is based, not on my handwriting or my chart templates, but on my decisions and on my clinical competence.

Free Tutorial

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Tim Richardson, PT owns a private practice at Medical Arts Rehabilitation, Inc in Palmetto, Florida. The clinic website is at MedicalArtsRehab.com.

Bulletproof Expert Systems: Clinical Decision Support for Physical Therapists in the Outpatient Setting is a manager's workbook with stories, checklists, charts, graphs, tables, and templates describing how you can use paper-based or computerized tools to improve your clinic's Medicare compliance, process adherence and patient outcomes.

Tim has implemented a computerized Clinical Decision Support (CDS) system in his clinic since 2006 that serves as a Reminder, Alerting, Prompting and Predicting CDS using evidence-based tests and measures.

Tim can be reached at
TimRichPT@BulletproofPT.com .

"Make Decisions like Doctors"

Copyright 2007-2010 by Tim Richardson, PT.
No reproduction without authorization.

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Consistent with the American Physical Therapy Association Vision Statement for Physical Therapy 2020, the American Physical Therapy Association supports exclusive physical therapist ownership and operation of physical therapy services.