Medicare Compliance & Reimbursement
Associations Team Up To Alleviate OT Headaches
A pair of trade groups has joined forces and taken issue with Medicare's rules regarding reimbursement on patients that need only occupational therapy.
The American Occupational Therapy Association and the National Association for Home Care and Hospice are planning to bend the Centers for Medicare and Medicaid Services' ear on a long-standing difference of opinion regarding OT as a qualifying service for home health.
The basics: CMS and its contractors maintain that for a home health patient to receive OT services, the OT must initiate those services before the patient receives the final qualifying PT, SLP or skilled nursing visit. "NAHC and AOTA believe that this policy is based on an incorrect interpretation of Medicare home health statutory language," NAHC explains.
CMS identifies the following as qualifying services, so long as they are certified as skilled services by a physician: nursing services, physical therapy services, speech-language pathology services, and "continuing occupational therapy services ... if the beneficiary's eligibility for home health services has been established by virtue of a prior need for intermittent skilled nursing care, speech-language pathology services, or physical therapy in the current or prior certification period" (42 CFR 409.42(c)).
Translation: CMS reads this regulation to mean that unless a patient receives OT services before discontinuing one of the other qualifying services, the OT is a "dependent service" and therefore is not covered.
AOTA and NAHC argue that this home health coverage regulation is based on a misrepresentation of an awkwardly written Medicare statute. The statute at Section 1814(a)(2)(C) of the Social Security Act says, "a homebound individual qualifies for home health when the individual needs or needed skilled nursing care ... on an intermittent basis or physical or speech therapy, or in the case of an individual who has been furnished home health services based on such a need and who no longer has such a need for such care or therapy, continues or continued to need occupational therapy."
The associations believe that when CMS wrote the coverage regulation, it inappropriately substituted "continuing occupational therapy" for the statutory language's "continues to need occupational therapy." "OT may be initiated and considered to be the qualifying service if the need for OT is identified and OT services are ordered prior to the patient being discharged for the qualifying service," NAHC says.
Medicare Compliance & Reimbursement
- ASC:
CMS Expands Procedure List By 60
More procedures will be covered in ASCs, and planned cuts are canceled.
Pressure from ambulatory surgery [...] - Long-Term Care:
Report: Action Needed To Avert Geriatric Care Crisis
Payment system discourages medical students from geriatric path.
While the U.S. population is aging rapidly, medical [...] - Long-Term Care:
Medicare Payments On Uptick Despite Debate
MedPAC's cautions all but ignored in new rule.
The Medicare Payment Advisory Commission suspects that the [...] - Pharmaceuticals:
CAP Shouldn't Require Exact Date Of Drug Admin
Associations object to 'radical' change in drug-billing window.
Now that the Centers for Medicare and Medicaid [...] - Hospitals:
Hot Specialty Hospital Issue Just Got Hotter
New bill would prohibit physician investor increases in 'grandfathered' specialty hospitals.
Just weeks away from the [...] - Physicians:
RAC Letters May Slip Through The Cracks
CMS will try to contact providers when it sends letters.
Given the high non-response rate to [...] - Physicians:
Know How To Cope With Altered Documentation
Tips for action when someone makes unauthorized revisions.
Physicians who suspect that someone in their practice [...] - Rehab:
75-Percent Rule Report May Up Admissions Scrutiny
Proposed refining of covered IRF diagnoses 'disappoints' some.
The long-awaited report from the Government Accountability [...] - Rehab:
Medicare Clarifies Tricky Therapy Supervision Issue
Physician must certify plan of care each month.
Providers confused about how to supervise therapists providing [...] - Enforcement Watch:
Providers Blow It With Ihnalant Overpricing
Giving free samples and rebates to pharmacies? It's not the best idea.
Defrauding Medicaid for 11 [...] - Home Health:
Associations Team Up To Alleviate OT Headaches
If CMS makes OT a qualifying service, scheduling could get a whole lot easier.
A pair [...] - Bill Watch
The following bills were introduced in the House: H.R. 2257. A bill to amend title [...] - Rehab:
Medicare Seeing Vision Demo Through
Project will give rehab pros more equity. Later this year, the Centers for Medicare and [...]
