Medicare Compliance & Reimbursement

Warning: CMS is on the lookout for providers who team up and game the system.

If you provide treatment to a patient with another therapist - or if two assistants provide treatment together - don't bill for the full session for each provider. If you do, you're begging for an audit.

Therapists providing co-treatment (or "team therapy") must either split the billing or decide which one will bill for the entire session, Centers for Medicare & Medicaid Services makes clear on its Medicare Part B Therapy Billing site.

Example: "A PT and an OT work together for 30 minutes with one patient on transfer activities," CMS posits. "The PT and OT could each bill one unit of CPT 97530 . Alternatively, the two units of 97530 could be billed by either the PT or the OT, but not both."

Along the same lines, if two PTAs provide the same treatment to the same patient at the same time, one supervising therapist could bill for the full service of one assistant - or the supervising therapist(s) could split the service between the two assistants.

This requirement can be frustrating for therapists, who are evaluated based on their productivity, notes consultant Darlene Greenhill with Maudlin & Jenkins in Atlanta. Consequently, most clinicians choose to split the charge, rather than handing it over entirely to one or the other, says consultant Ann Lambert Kremer with Beacon Rehab Solutions in Portland, ME.

If the therapists each bill for the entire session, they're clearly breaking the rules, experts agree. Billers and therapists should work together to ensure they're not double billing, Greenhill advises. "Therapists should be educated on the billing rules and be willing to communicate and work with each other to avoid misunderstandings and problems."