Home Health & Hospice Week

Don't miss out on new Part B therapy guidance or you could risk billing or compliance trouble.

The Centers for Medicare & Medicaid Ser-vices has issued a 53-page transmittal (Transmittal No. 88) that spells out just about everything you need to bill for therapy services. The document also offers updates to outpatient rehab policies.

For example: CMS now specifies that the therapy duration is the number of weeks, or the number of treatment sessions, "for THIS PLAN of care."

In addition, CMS notes, "the frequency or duration of the treatment may not be used alone to determine medical necessity, but they should be considered with other factors such as condition, pro-gress, and treatment type to provide the most effective and efficient means to achieve the patients' goals."

Keep in mind: Many of the updated regulations in the transmittal simply put into writing already-existing requirements for many carriers. Now, these regulations are in writing to allow for uniform billing rules between payers.

One important area fleshed out is therapy aides. Medicare and most other payers require that a physical therapist, physician or nonphysician practitioner furnish physical therapy. And most payers will not cover the services of a therapy assistant or aide as the primary therapy caregiver.

The therapy notes have to reflect who performed the service. This may determine whether Medicare or the insurance company will pay for the service or not, says Jay Neal, an independent coding consultant in Atlanta.

The transmittal also makes clear that you need to meet the standards of a PT by creating a therapy plan specifically geared to each patient and his specific complaint. The main goal of this documentation should be to justify why a particular patient requires -- and would benefit from -- these services.

An effective PT patient file should include the following:

• A written treatment plan that the clinician creates after an appropriate assessment of the condition (illness or injury). Include documentation of the history, examination, diagnosis, therapy goals and potential for achievement, any contraindications, functional assessment, type of treatment, the body areas to be treated, the date that the therapy was initiated, and expected frequency and duration of treatments.

• Prognosis for potential restoration of function in a reasonable and generally predictable period of time or the need to establish a safe and effective maintenance program.

• Indication that the therapy is working or not working. "This is important to show whether continuation is appropriate," says Shannon Mills with Mills Billing.

Note: The transmittal is available at www.cms.hhs.gov/transmittals/downloads/R88BP.pdf.