Orthopedic Coding Alert

Ever since CMS changed the physician -incident-to- guidelines for servicing Part B outpatient physical therapy services in June 2005, many orthopedic practices are asking themselves if they should hire a physical therapist in order to be compliant with the new requirements.

However, some of the issues that are holding them back are A) What would be the best business relationship to have? B) What would be the benefits of this relationship? and C) What do I need to know when hiring a therapist?

The purpose of this article is to clarify these questions and assist physicians in making the decision that would be right for their practice. Issue A: What would be the best business relationship to have? There are two different relationships a practice can have with a licensed physical therapist: the first relationship is as a direct employee of the practice, and the second is as an associate of the practice. So what is the difference?

Relationship 1: As an employee of the practice, the PT will be working under the incident-to regulations. This means that -therapy services must be provided by or under the direct supervision of a physician (a doctor of medicine or osteopathy) who is legally authorized to practice therapy services by the state in which he or she performs such function or action,- according to chapter 15 of the Medicare Benefit Manual Pub. 100-02.

-Direct supervision requires that the supervising physician be present in the suite and immediately available to assist during the procedure.-

Responsibilities of the physician: Direct supervision means that the physician cannot leave the office suite during the time that the PT is performing services, according to Medicare guidelines. The physician must also demonstrate that -the physician's initial service, direct supervision of therapy services, and subsequent services must be of a frequency which reflects their active participation in and management of the course of treatment,- according to the Benefit Manual.

The physician is also responsible for reviewing the plans of care (POCs) and certification/recertification of treatment. The physician can, if he chooses, perform the evaluation and develop the POCs; if they do this, they must follow all of the guidelines for documentation as listed in the Section 220 of the Benefit Manual.

Responsibilities of the therapist: The PT does not have to have his own National Provider Identifier (NPI) number, because the Medicare services he will provide will be billed under the associated physician's NPI and assigned to the group practice if applicable. The therapist must follow the guidelines for documentation of services as identified for all other sites of service, including evaluation, daily notes, progress reports, and updated POCs.* 
 
Relationship 2: As an associate of the practice, the PT is practicing as a therapist [...]