Home Health & Hospice Week

Add progress reports, outcomes to your outpatient therapy to-do list.

In conjunction with its therapy cap changes, Medicare now has some new Part B therapy documentation guidelines you'd better get a handle on.

Home health agencies that furnish outpatient therapy should check out a new Centers for Medicare & Medicaid Services transmittal updating therapy documentation--or risk claims denials.

"Contractors shall, on pre- or post-pay medical review, require Progress Reports to be written by clinicians once during each Progress Report Period," CMS states in Dec. 29, 2006 Transmittal 63. So, "the progress report is going to be required even if the exceptions process goes away," says physical therapist John Wallace of BMS Reimbursement Management in Claremont, CA.

On the other hand, the elements of the progress report can be in your daily treatment notes or in your updated plan of care, Wallace adds. In fact, the transmittal states, "when required elements of the Progress Report are written into the Treatment Notes or in a Plan of Care, the contractors shall accept it as fulfilling the requirement for a Progress Report; a separate Progress Report shall not be required."

Helpful: The progress report "doesn't have to be a separate document if the required elements are in another place in your documentation," Wallace clarifies. "So that helps the redundancy issue."

Option: Use 1 Care Plan For 2 Physicians

Although a patient may be under the care of two physicians, the transmittal clarifies that you can combine the plans of care, which can be signed by just one of the doctors if they are willing to do so, Wallace tells Eli.

Alternatively, the therapy provider can maintain two separate plans of care, and each physician would sign the plan of care for which they referred the patient for therapy services.

"When a patient is being treated under the care of two physicians for separate conditions, contractors shall accept as appropriate documentation either a combined plan of care certified by one of the physicians /NPPs or two separate plans of care certified by separate physicians/NPPs," CMS states in the transmittal.

4 New Therapy Outcomes

CMS is recommending four therapy outcomes measurement instruments to better support medical necessity, according to Transmittal 63. They are:

• National Outcomes Measurement System (NOMS) by the American Speech-Language Hearing Association (ASHA);
• Patient Inquiry by Focus On Therapeutic Outcomes Inc. (FOTO);
• Active Measure-Post Acute Care (AM-PAC); and
• OPTIMAL by Cedaron, through the American Physical Therapy Association (APTA).

Occupational therapists: If you're wondering why your professional association doesn't have an outcomes tool on CMS' list, don't worry. "We believe that if you follow the best practice as our guidelines define it, you'll meet these CMS criteria," says Chris Metzler with the American Occupational Therapy Association.

Know Your Back-Up

 If you're one of the vast majority of therapists who does not use these instruments, Transmittal 63 outlines the required alternative. But first, it asks all therapists--regardless of whether they use the four recommended outcome measures--to build some groundwork with certain documentation, as applicable. For starters, you must include documentation that:

• Supports the illness severity or complexity;
• Supports medical care prior to the current episode;
• Indicates the beneficiary's quality of life; and
• Indicates the beneficiary's social support.

Bright side: Although this may sound like a handful, remember, "these are standard questions that an OT [and PT or SLP] asks when doing an evaluation," Metzler points out.

Your Outcome Measurements Are As Easy As 1-2-3

Once you've established this groundwork, if you choose not to use one of CMS' recommended outcomes tools, you instead must submit documentation indicating "objective, measurable beneficiary physical function," including at least one of these three items:

1) Functional assessment individual item and summary scores from commercially available therapy outcomes instruments. "An example of a commercially available measurement could be a FIM score," says PT Rick Gawenda, director of physical medicine and rehabilitation at Detroit Receiving Hospital.

2) Functional assessment scores from tests and measurements validated in professional literature. "A valid test could be results of a manual muscle test or a range of motion test," Gawenda adds.

3) Other measurable progress toward identified goals for functioning in the home environment after the therapy episode is finished. "This could be noting that the patient progressed from using a walker to a standard cane, or that the patient can now do upper extremity dressing," Gawenda points out.
 
The bottom line: If you've followed your professional documentation guidelines faithfully, you shouldn't have a problem with the new documentation requirements or the outcomes information. In fact, this shouldn't be new to you.

"People shouldn't be too intimidated by the red ink in the transmittal because when you compare what CMS is asking for to what AOTA has always suggested, it's not very different," Metzler says.

Note: For more information on Part B therapy, see Eli's Rehab Report at www.elihealthcare.com or by calling 1-800-874-9180.