Eli's Rehab Report

Tip: Protect against subsequent reviews by documenting medical necessity carefully.

Are you sure every single therapy re-eval you’ve done for a patient can stand up to scrutiny? If not, your reimbursement could be at stake.

New way: “Effective April 1, 2015, Palmetto GBA will require the Initial Therapy Evaluation, current therapy re-evaluation(s) for episode under review and the previous therapy re-evaluation(s) to be submitted with ANY Home Health Therapy records requested for review,” the Home Health & Hospice Medicare Administrative Contractor says in an April 1 post to its website.

In other words: “If an initial start of care was requested for review, include the Initial Therapy Evaluation and therapy re-evaluation(s),” the MAC directs. “On subsequent episodes, include the Initial Therapy Evaluation, current therapy re-evaluation as well as therapy re-evaluation immediately prior to the requested episode.”

Why? “This allows Medical Review to analyze medical necessity of services billed,” Palmetto explains in its post.

Old way: Formerly, Palmetto typically reviewed a specific episode of care, notes PT consultant Cindy Krafft with Kornetti & Krafft Health Care Solutions. “This is taking the medical necessity issue specifically to patients who are recertified by asking for the initial therapy evals and reassessments even if they are in a previous cert period.”

The new policy “is a wake-up call about the importance of the documentation on assessments and reassessments in terms of supporting medical necessity,” Krafft tells Eli. 

Note: To see the notice, go to www.palmettogba.com/medicare, click on “J11 MAC Home Health and Hospice” in the left-hand column, then choose “General” under the “Medical Review” link on the left, then click on the April 1 “Home Health: Therapy ADRs” link in the list of articles.