"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

Showing posts with label Medicare auditors. Show all posts
Showing posts with label Medicare auditors. Show all posts

Tuesday, November 15, 2011

Error Rate Among Medicare Auditors High

Recovery Audit Contractors (RAC) have recovered more dollars in 2011 than they did in 2010 but this metric of success may overstate their value.

A Washington Post story from yesterday, November 14 2011, shows that Medicare auditors make overpayment determinations based on "inaccurate data".

RAC activity in 2011 was centered in the West and the Southern United States.

StateOverpayment
Florida$7.1 million
California$7.7 million
Washington$5.3 million
Texas$5.8 million


"The error rate in the Medicare RAC process is disturbingly high, especially since the cost of filing an appeal can be prohibitive," said AMA President Peter W. Carmel, MD.

"The AMA is working with CMS to improve this process and decrease the financial and administrative burden on physicians."
A 2010 Office of the Inspector General (OIG) report found that CMS...
"...did not sufficiently oversee the RACs during the demonstration project to ensure the vulnerabilities pursued by RACs were valid and that RACs made accurate improper payment determinations.

According to provider associations, this led to numerous appeals of inaccurate RAC determinations that were expensive and burdensome for providers."
Physical therapists can reduce their risk of a RAC audit, or any Medicare audit by following the seven components of the OIG Compliance Program for Individual and Small Group Physician Practices.

Also, join the email tutorial in the sign-in boxes above or below this post.

Saturday, February 13, 2010

Physical Therapy Process Beats Outcome

The current tally of officially recognized 'process' vs. 'outcome' measures in health care from the National Quality Measures Clearinghouse (NQMC) favors 'Process' over 'Outcome' by 997 to 368.

If physical therapists define quality by 'how' we deliver care over 'how much better' our patients get - then our patients are in trouble.

nqmc screenshot
click image to view larger size


Why is this important?

Outcomes-based care is where the United States health care system is going.

Physical therapists can be leaders in this transition. The adoption of outcome measurement by our profession will the the 'speedometer' by which that transition is gauged and will ultimately decide the winner.

Unfortunately, the adoption of evidence-based outcomes tools is slowed by the burden of 'process-based' measures in physical therapists' clinics.

A partial list of some 'un-official' process measures in physical therapy:
  • Therapy cap exceptions process (-kx modifier)
  • ‘Skilled therapy’
  • 10th visit progress note
  • 90-day certification of the plan of care
  • Physician signature of the plan of care
  • AMA definition of physical therapy practice (via 15-min CPT codes)
  • Automatic CPT coding edits
  • 1-on-1 procedure codes
  • time-in & time-out
  • Medicare Minimal Documentation Requirements
  • ‘8-min. rule’
  • Discharge from physical therapy
These process measures, that dictate 'how' physical therapy is provided, all but eliminate the time, energy and money required for investments in true quality.

Where does all the time and money go?

Physical therapists nationwide (~177,000), especially those working in outpatient therapy clinics (~65,000) are burdened by excessive documentation of uncertain value - the primary reason for documentation seems to be to protect ourselves from Medicare audits.

Witness this description of the 'process-oriented' note that is supposed to accompany the billing of one, single code for Therapeutic Exercise (CPT 97110):
"Quadriceps strengthening into last 20 degrees of extension with mild manual resistance and proprioceptive cueing, 30 reps to fatigue, continues to decrease current extension lag and improve quality and duration of gait"
This description was made by Medicare auditor and former private practice physical therapist Steve Levine, DPT in a February 3rd, 2010 webinar called "Will Your Documentation Trigger an Audit?"

Dr. Levine's recommendation to over 400 members of the webinar cast a chilling pall over the prospects for improvements in the rate of physical therapists' adoption of outcome measures in the short-run.

The very last question in the webinar was posed by a physical therapist clearly non-plussed by the idea that every 1-on-1 procedure code need to be accompanied by this lengthy, narrative description.

Dr. Levine did not relent, implying that we need to spend as much time writing justifications for our care as we spend providing our care.

Some Process Measures are not statutorily based

Keep in mind that Dr. Levine's recommendations are just that - recommendations.

The Medicare Minimal Documentation requirements do not specifically require this level of narrative:
"...a therapist’s skills may be documented, for example, by the clinician’s descriptions of their skilled treatment, the changes made to the treatment due to a clinician’s assessment of the patient’s needs on a particular treatment day or changes due to progress the clinician judged sufficient to modify the treatment toward the next more complex or difficult task...

Documentation should establish the variables that influence the patient’s condition, especially those factors that influence the clinician’s decision to provide more services than are typical for the individual’s condition...

...Documentation should establish through objective measurements that the patient is making progress toward goals...

...It is recommended that the reasons for lack of progress be noted and the justification for continued treatment be documented if treatment continues after regression or plateaus."
(Transmittal 88, page 25-26)
I could have written Dr. Levine's narrative description in 1992 - the year I graduated from PT school. Why should I write it now, in 2010?

Are we all crooks?

Is physical therapy still practiced the way they taught me then? I don't think so - today we have evidence-based physical therapy (the term was only invented in 1991).

Surely the profession could come to a consensus on what constitutes 'skilled physical therapy' that incorporated the best, up-to-date evidence on screening for pathology, treatment based classification and interventions supported by grade 'A' or 'B' trials rather than case studies or anecdote.

Right now we are abdicating our profession to self-serving, ex-clinicians with out-of-date treatment paradigms.

Why couldn't Federally mandated evidence-based outcome measures supercede process-based time-wasters? Let's bring Medicare audits (and Medicare auditors) into the 21st century.

Let's reverse the score: 997 to 368 Outcomes over Process.

Thursday, January 15, 2009

The Medicare Taxonomy for Physical Therapists

I am not a doctor.

I don't even play one on T.V.

I don't have a Ph.D.

I don't have a Doctor of Physical Therapy (DPT).

I'm a physical therapist (PT).

That's it.

And, I present material in this blog that some people may associate with post-graduate instruction, legal advice or consulting on Medicare compliance.

That would be a mistake.

All I do is treat patients with physical therapy, write my notes and try to understand our nation's Medicare program as it applies to outpatient physical therapy services.

To help the process of Medicare compliance I created my alternate website, Bulletproof Physical Therapy Notes and Charts with free government and professional resources on making a do-it-yourself Medicare compliance program.

Isn't that the way most physical therapists are?

Resourceful?

Ultimately, I intend to create a taxonomy that students and non-professionals can use to understand the work we physical therapists do for our Medicare patients.

It's crazy that I can describe Medicare with taxonomy, a word originally used to describe the complexity of living organisms.

Now, Medicare compliance is completely the jurisdiction of "Medicare auditors"
  • un-elected

  • un-licensed (as auditors)

  • non-peer reviewed
..."experts" that get paid to look at your notes.

Don't get me wrong - everybody deserves a chance to make a living - even Medicare auditors.

The $3 billion Medicare program needs auditors - to catch the bad guys.

That $3 billion attracts a lot of bad guys.

But, physical therapists usually aren't bad guys (or girls).

What physical therapists need is a simpler, less intimidating process to...
  • document our findings
  • show medical necessity
  • show progress
  • show skilled decisions
  • help patients without taking ridiculous risks
Am I the only one who thinks this way?

Free Tutorial

Get free stuff at BulletproofPT.com

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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