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The analysis of any legal or medical billing is dependent on numerous specific facts — including the factual situations present related to the patients, the practice, the professionals and the medical services and advice. Additionally, laws and regulations and insurance and payer policies are subject to change. The information that has been accurate previously can be particularly dependent on changes in time or circumstances. The information contained in this web site is intended as general information only. It is not intended to serve as medical, health, legal or financial advice or as a substitute for professional advice of a medical coding professional, healthcare consultant, physician or medical professional, legal counsel, accountant or financial advisor. If you have a question about a specific matter, you should contact a professional advisor directly. CPT copyright American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.

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Plan of Care FAQs

See our Medicare Plan of Care section for more guidance.

Who can establish a therapy plan of care (POC)?

Outpatient therapy services shall be furnished under a plan established by:

    • A physician/NPP (consultation with the treating physical therapist, occupational therapist, or speech-language pathologist is recommended. Only a physician may establish a plan of care in a CORF;
    • The physical therapist who will provide the physical therapy services;
    • The occupational therapist who will provide the occupational therapy services; or
    • The speech-language pathologist who will provide the speech-language pathology services.

Who must sign the POC?

The person who established the plan must sign and date the plan.  The physician/NPP must also certify the plan by signing and dating it.

See Certification for more information.

Can treatment begin before a POC has been established?

Treatment may begin before the plan is committed to writing only if the treatment is performed or supervised by the same clinician who establishes the plan. Payment for services provided before a plan is established may be denied.

What must be included in the POC?

The plan of care shall contain, at minimum:

    • Diagnoses;
    • Long term treatment goals; and
    • Type, amount, duration and frequency of therapy services.

References

Medicare Benefit Policy Manual Ch. 15 – Covered Medical and Other Health Services §220.1.2

Billing and Coding: Outpatient Physical and Occupational Therapy Services: A57067

About Us

Zachary Edgar JD, LLM is the managing partner for Therapy Comply.  Zachary is a healthcare attorney that specializes in federal and state healthcare regulatory issues particularly for physical, occupational, and speech therapy practices.  

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