"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

Wednesday, December 30, 2009

An Open Letter to Florida Medicare (First Coast Service Options)

This author's continued investigation into the new Medicare policy of Skilled Maintenance Therapy for Safety will be published on this blog for your edification and comment.

The following letter was sent to medical.policy@fcso.com 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):

"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.

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."
However, the LCD goes on to clarify the clinical situation:
"It is not medically necessary for a therapist to perform or supervise maintenance programs that do not require
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;"
The 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).

On the face of it, the new LCD language appears contradictory.

I wonder if you could provide some guidance?

Thank you.

Tim Richardson, PT

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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 .

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Copyright 2007-2010 by Tim Richardson, PT.
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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.