Heads Up! Physical Therapists in Private Practice (PTPP)

The annual issuance of the Office of the Inspector General's (OIG) 2010 Work Plan sets the tempo for all subsequent Medicare audits - since the OIG is the agency that actually audits Medicare (CMS).

Here is what the Work Plan actually says about physical therapists in private practice:

"Outpatient Physical Therapy Services Provided by Independent Therapists

We will review outpatient physical therapy services provided by independent therapists to determine whether they are in compliance with Medicare reimbursement regulations.

The Social Security Act, § 1862(a)(1)(A), provides that Medicare will not pay for items or services that are “not reasonable and necessary for the diagnosis and treatment of illness or injury or to improve the functioning of a malformed body member.”

CMS’s “Medicare Benefit Policy Manual,” Pub. No. 100-02, ch. 15, § 220.3, contains documentation requirements for therapy services.

Previous OIG work has identified claims for therapy services provided by independent physical therapists that were not reasonable, medically necessary, or properly documented.

Focusing on independent therapists who have a high utilization rate for outpatient physical therapy services, we will determine whether the services that they billed to Medicare were in accordance with Federal requirements.

(OAS; W-00-10-35220; various reviews; expected issue date: FY 2010; new start)"
(page 29)

Physical therapists in Private practice should focus their attention on two areas to make sure that their compliance plan meets Medicare requirements:

Process Measures such as the following:

• 8-minute rule
  
  
• -kx modifiers and the arbitrary PT caps
  
  
• PT/PTA supervision requirements
  
  
• Medicare Minimal Documentation requirements
  
  
• ‘Skilled physical therapy’
  
  
• One-on-one procedure codes
  
  
• Untimed modality codes
  
  
• -59 modifiers and CPT code edits
  
  
• Physician certification of the physical therapy plan of care

Evidence-based physical therapists who truly care about their patients and about the job we do will also want to direct their attention to Outcome Measures such as the following:

• Patient self-report outcomes and questionnaires (eg: OPTIMAL, LEFS, etc.)
  
  
• Therapist-administered performance tests (eg: Gait Velocity, TUG Test, etc.)
  
  
• Impairment-level tests and measures (eg: SLR, neck rotation, etc.)

Finally, one self-administered process measure is Treatment Based Classification (TBC), which has the potential to...

• save costs,
  
  
• improve outcomes and
  
  
• elevate physical therapist decision making

TBC can show Medical Necessity and Skilled Therapy - two important areas of Medicare Minimal Documentation requirements.

To learn more about TBC and Medicare compliance you can attend one of the Classification Seminars in Palmetto, Florida on November 7th or 21st at the Medical Arts Rehabilitation physical therapy clinic from 9am to 4pm.

You can sign-up online at BulletproofPT.com