The following letter was sent to firstname.lastname@example.org after the normal FCSO Medicare customer service reps were stymied by my questions.
Dear Medicare Policymakers,
The new (2/2/09) LCD for Therapy & Rehab Part B services (L29289) has new instructions for physical therapists (page 21):
Skilled MAINTENANCE THERAPY for Safety"If the services required to maintain function involve the use of complex and sophisticated therapy procedures, the judgment and skill of a therapist may be necessary for the safe and effective delivery of such services.However, the LCD goes on to clarify the clinical situation:
When the patient’s safety is at risk, those reasonable and necessary services shall be covered even if the skills of a therapist are not ordinarily needed to carry out the activities preformed as part of the maintenance program.""It is not medically necessary for a therapist to perform or supervise maintenance programs that do not requireThe most likely clinical scenario in outpatient physical therapy clinics is when the PT assess a patient likely to fall (complex and sophisticated services = skilled) on a patient whose exercises are necessarily low-level and repetitive (for feeble and unstable patients).
the professional skills of a therapist.
These situations include...
· repetitive exercises to maintain gait or maintain strength and endurance, and assisted walking, such as that
provided in support for feeble and unstable patients;"
On the face of it, the new LCD language appears contradictory.
I wonder if you could provide some guidance?
Tim Richardson, PT