Medicare Compliance & Reimbursement

Plus: Your progress report deadlines aren't what they used to be When the Medicare Physician Fee Schedule Final Rule hit the press last November, rehab providers were happy to see certification periods extend to 90 days on Jan. 1, 2008. If you've been applying this new guideline since the beginning of the year, you're on the right track, but CMS has a few more bones to pick when it comes down to the details. Read on to learn more about what recently released CMS transmittal 88 (CR 5921) has to say about your physician certifications. 90 Days Isn't Always The Magic # For POCs One of the first points the transmittal brings up is that certification intervals aren't automatically 90 days. Instead, they may be "90 calendar days or less, based on an individual's needs," CMS states (emphasis added). This was implemented on June 9 and retroactive to Jan. 1. Example: Suppose you do an evaluation of a Medicare patient and establish a plan of care for therapy two times a week for eight weeks. "When the physician signs and dates that plan of care, the certification will only be valid for those 16 visits -- which would equal out to about 56 days, as opposed to 90," explains Rick Gawenda, PT, director of PM&R at Detroit Receiving Hospital and owner of Gawenda Seminars. In fact, "most plans of care are not going to be developed for 90 days; this policy just allows the therapist the freedom to establish longer care plans that are 'up to 90 days' if needed." Don't miss: Although your initial certification interval can be up to 90 days, that doesn't mean you can wait that long for the physician's signature. You must obtain a physician's (or NPP's) signature within 30 days of the initial treatment date or significantly modified plan of care, says Ellen Strunk, PT, MS, GCS, owner of Rehab Resources and Consulting in Birmingham, AL. For initial certifications, remember that the first day of treatment includes your evaluation, CMS stresses. For recertifications, CMS considers them timely "when dated during the duration of the initial plan of care or within 90 calendar days of the initial treatment under that plan, whichever is less." Know The New Progress Report Deadlines When CMS changed the certification interval to a maximum of 90 days last November, therapy progress report guidelines suddenly became a little fuzzier. Previously, progress reports were due once every 10 visits or once every certification interval -- whichever came first. But with the much longer, 90-day certification interval, that ruling was a bit outdated. The result: In this transmittal, CMS changed the requirement to state that progress reports are due once every 10 visits or once every [...]