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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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Site Updates

  • New NCCI Section

    8 Feb 2021 11:49 AM | Zachary Edgar (Administrator)

    Please enjoy our new NCCI section for therapy services.   Each section has been updated to the new January 2021 edits. 

    Procedure to Procedure (PTP) Edits 

    • PTP Basics
    • Using Modifier 59 and X~ Modifiers
    • PTP Hospital Edits
    • PTP Practitioner Edits 

    Policy for Physical Medicine and Rehabilitation - January 1, 2021 (updated yearly)

    • Multiple Evaluations on the Same Day
    • Evaluations and other Assessment Codes
    • Billing more than one Service in a 15 Minute Period
    • Re-evaluations
    • Re-evaluation and Orthotic/Prosthetic Management
    • Assistive Technology Assessment
    • Manual Therapy Techniques and Therapeutic Activities (Removed Jan. 1, 2021)
    • Wound Debridement and Surgical Debridement
    • Cardiac Rehabilitation and other Therapy Services
    • Ultrasound and Wound Care

    Medically Unlikely Edits - January 1, 2021

    • Physical Therapy Evaluations and Reevaluations
    • Occupational Therapy Evaluations and Reevaluations 
    • Speech Therapy 
    • Modalities 
    • Therapeutic Procedures
    • Assessments and Orthotics/Prosthetics 
    • Range of Motion and Canalith
    • ADL and Work Conditioning 
    • Wound Care
    • Biofeedback Training


  • Arizona Physical Therapy Business Entities

    26 Oct 2020 1:38 PM | Zachary Edgar (Administrator)

    Definitions

    "Business entity" means a business organization that has an ownership that includes any persons who are not licensed or certified to provide physical therapy services in this state, that offers to the public professional services regulated by the board and that is established pursuant to the laws of any state or foreign country.

    Requirement to register a business entity

    Beginning September 1, 2011, a business entity shall not offer physical therapy services unless:

    • The business entity is registered with the board; or
    • The physical therapy services are conducted by a licensed physical therapist or certificated physical therapy assistant.

    A business entity that offers physical therapy services to the public and is not exempt from registration shall separately register with the Board each location from which physical therapy services are offered in Arizona.

    Practices exempt from registration

    A sole proprietorship or partnership that consists exclusively of persons who are licensed by a health profession regulatory board.

    A facility regulated by the federal government or a state, district or territory of the United States.

    An administrator or executor of the estate of a deceased physical therapist or a person who is legally authorized to act for a physical therapist who has been adjudicated to be mentally incompetent for not more than one year from the date the board receives notice of the physical therapist's death or incapacitation.

    A health care institution that is licensed pursuant to title 36.

    A facility that offers physical therapy services to the public must be registered by the board unless the facility is any of the following:

    • Owned by a licensee.
    • Regulated by the federal government or a state, district or territory of the United States.

    What is required for the application?

    To register with the Board an Arizona location at which physical therapy services are offered, a business entity shall submit to the Board an application packet that includes the following:

    An application form, which is available from the Board and requires the following information:

    • Name, primary address, and e-mail address of the business entity;
    • Name, title, address, e-mail address, and telephone number of the manager of the location being registered;
    •  Name and business address of each officer or director of the business entity; 
    • Name and license number of each physical therapist who provides physical therapy services at the location being registered;
    • Name and certificate number of each physical therapy assistant who works at the location being registered;
    • Description of the physical therapy services offered at the location being registered;
    • For the business entity, a statement of whether any state, territory, district, or country has ever:
      • Refused to issue or renew a registration, permit, license, or other authorization;
      • Accepted surrender of a registration, permit, license, or other authorization in lieu of other disciplinary action; or
      • Suspended, revoked, cancelled, or taken other disciplinary action against a registration, permit, license, or other authorization; and
    •  Dated signature of an officer or director attesting that:
      • The business entity has a written protocol that meets the standards in A.R.S. § 32-2030(F) for the secure storage, transfer, and access of the physical therapy records of the business entity’s patients; and
      • The information provided is true and correct.

    The application fee for a business entity:

    • Application for an original registration, $50;
    • Renewal, $50;
    • Late fee, $25; and
    • Duplicate registration, $10.

    Required written protocols

    The business entity must establish and implement a written protocol for the secure storage, transfer and access of the physical therapy records of the business entity's patients. This protocol must include, at a minimum, procedures for:

    • Notifying patients of the future locations of their records if the business entity terminates or sells the practice.
    • Disposing of unclaimed physical therapy records.
    • The timely response to requests by patients for copies of their records.

    Required display of the certificate

    For each location registered, a business entity shall display, in a location accessible to public view, the:

    •  Registration certificate and current renewal verification of the business entity,
    • License and current renewal verification of every physical therapist who provides physical therapy services at the location, and
    • Certificate and current renewal verification of every physical therapy assistant who works at the location.

    Registration renewal

    The registration of a business entity expires for each location registered on August 31 of every odd-numbered year. The business entity shall separately renew the registration of each location from which the business entity offers physical therapy services in Arizona.

    To renew the registration of an Arizona location from which physical therapy services are offered, a business entity shall submit to the Board an application form, which is available from the Board and requires the following information:

    • Name, primary address, and e-mail address of the business entity;
    • Name, title, address, e-mail address, and telephone number of the manager of the location being registered;
    • Name and business address of each officer or director of the business entity;
    • Name and license number of each physical therapist who provides physical therapy services at the location being registered;
    • Name and certificate number of each physical therapy assistant who works at the location being registered;
    • Description of the physical therapy services offered at the location being registered;
    •  For the business entity, a statement of whether any state, territory, district, or country has ever:
      • Refused to issue or renew a registration, permit, license, or other authorization;
      • Accepted surrender of a registration, permit, license, or other authorization in lieu of other disciplinary action; or c. Suspended, revoked, cancelled, or taken other disciplinary action against a registration, permit, license, or other authorization;
    • Statement of whether the business entity complies with A.R.S. § 32-2030(F); and
    • Dated signature of an officer or director attesting that the information provided is true and correct

    Reference

    A.R.S. § 32-2001

    A.R.S. § 32-2030

    A.A.C. R4-24-210

    A.A.C. R4-24-107

    A.A.C. R4-24-211

  • Current Plan for the Website

    23 Oct 2020 2:18 PM | Zachary Edgar (Administrator)

    I have prepared a lot of new and updated material for the website.  The plan is to upload 3-4 states a week that will include the PT, OT, and SLP FAQs and Medicaid material.  I will also be adding new material to Medicare, Tricare, HIPAA, and compliance sections.  

    If you have any questions or suggestions, please email me at zedgar@med-comply.com


  • Ohio Physical Therapy FAQS

    5 Aug 2020 1:09 PM | Zachary Edgar (Administrator)

    FAQs

    Continuing Education

    • How many continuing education hours are required during a reporting period?
    • How long is the reporting period?
    • When are CE requirements due?
    • How is credit hour defined?
    • Can CE credits be carried over into the next reporting period?
    • Are there any specific courses that must be taken?
    • What types of activities can be used for the continuing education requirements?
    • Are there limitations on the types of courses that can be taken?
    • What type of approval is needed for the courses?
    • What type of courses or activities are not allowed?
    • What are the reporting requirements?
    • How long must continuing education records be retained?
    • Can I get a waiver for my CE requirements?
    • What happens if I am audit?

    Scope of Practice

    • How is the practice of Physical Therapy defined in Ohio?
    • What is included in the practice of PT?
    • Services specifically excluded from the scope of practice
    • Can PTs practice dry needling?
    • Can PTs administer topical drugs?
    • Can PTs practice through telehealth?

    Direct Access and Referrals 

    • Is a referral required to provide PT services?
    • Exceptions to the referral requirement?
    • Which providers can issue the referral?
    • How can PTs receive referrals?
    • When does a PT have to refer a patient to a physician?

    Supervision and Delegation

    • Definitions
    • Which services can only be performed by a licensed physical therapist?
    • What are the responsibilities of the PT when delegating?

    Assistants

    • Which services are PTAs allowed to practice?
    • Are there specific services that PTAs are prohibited from practicing?
    • What type of supervision is required?
    • Who is the supervising physical therapist?
    • What are the assistant’s documentation responsibilities?
    • Does the supervising physical therapist need to co-sign documentation created by the PTA?
    • What is the ratio between supervising PTs and PTAs?
    • Required designation for assistants

    Aides

    • What can an aide do?
    • What is an aide expressly prohibited from doing?
    • What type of supervision is required?
    • What is the ratio between supervising PTs and aides?
    • Required designation for aides

    Students 

    • Can students practice in a clinical setting?
    • What kind of supervision is required for student PTs and PTAs?
    • Documentation – Cosignatures 
    • Identification of students

    Identification and Notification

    • How can I use “Dr” in my title?
    • Are there any specific requirements for posting notifications or licenses?
    • When does a PT have to notify the board of any information changes?

    Out-of-State PT and PTAs

    • Can I practice in state if I am licensed in another state?
    • What is the process for getting reciprocity in Ohio?
    Military Service Provisions
    • Definitions
    • Eligibility for licensure
    • License Renewal
    • Continuing Education
    • Waiver of license application fee

    Forms of Business Authorized to Practice 

    • Which forms of business entities can a PT practice under?
    • Who may form the business entity?
    Unprofessional Conduct
    • When does a PT need to report to the board?
    • Conduct that may result in an offense


  • Texas Medicaid: Claims for Telehealth Service for Occupational, Physical, and Speech Therapy

    14 Apr 2020 2:09 PM | Zachary Edgar (Administrator)

    Managed Care

    Texas Medicaid managed care organizations (MCOs) must provide all medically necessary, Medicaid-covered services to eligible clients. Administrative procedures such as prior authorization, pre-certification, referrals, and claims/encounter data filing may differ from traditional Medicaid (fee-for-service) and from MCO to MCO. Providers should contact the client's specific MCO for details.

    Effective Dates

    Effective for dates of service March 15, 2020, through April 30 2020, authorized occupational, physical, and speech therapy for clients of all ages may be delivered as a telehealth service.

    Telehealth therapy services must be delivered within the provision of current licensure requirements found in Occupational Therapy Rules, Physical Therapy Rules, and Speech-Language Pathologists and Audiologists Administrative Rules. See Texas Medicaid for more information.

    Modifiers

    Providers should use the 95 modifier to indicate remote delivery. Providers are reminded to use the required modifiers GP, GO, and GN on all claims for physical, occupational, or speech therapy treatment.

    Prior Authorization

    There will be no changes to the prior authorization submission process. A separate prior authorization is not needed solely to allow for the remote delivery of therapy services.

    Evaluations

    Evaluation, re-evaluation, and treatment may be delivered via telehealth as determined clinically appropriate by the rendering therapist and in compliance with each discipline’s rules.

    Assistants

    Therapy assistants may provide telehealth and receive supervision within limits outlined in each discipline’s rules. Providers should refer to state practice rules and national guidelines regarding supervision requirements for each discipline. See Texas Physical Therapy Assistants or Texas Occupational Therapy Assistants.

    Informed Consent

    Telehealth requires consent from the client or responsible adult. Verbal consent is permissible and should be documented in the client’s medical record. Teletherapies may require participation of a parent or caregiver to assist with the treatment.

    Services that Cannot be Performed via Telehealth

    Clinical evaluations required for the provision of new complex rehabilitation technology, such as power mobility and adaptive seating systems or augmentative  communication devices, require the physical presence of the speech-language pathologist, the occupational therapist, or physical therapist and should not be delivered via telehealth unless exceptional medical circumstances exist.

    Treatment Notes

    Treatment notes should indicate that remote delivery of the service is clinically appropriate per the treating therapist’s professional judgement.

    HIPAA

    The Office of Civil Rights (OCR) has relaxed Health Insurance Portability and Accountability (HIPAA) requirements to allow for the use of additional video capabilities to deliver service via telehealth. Texas Medicaid will recognize OCR’s HIPAA enforcement discretion as it relates to telehealth platform requirements.

    Reference

    Claims for Telehealth Service for Occupational, Physical, and Speech Therapy. April 14, 2020 available at http://www.tmhp.com/News_Items/2020/04-April/04-14 20%20Claims%20for%20Telehealth%20Service%20for%20Occupational,%20Physical,%20and%20Speech%20Therapy.pdf


  • Florida Physical Therapy Updates and Changes

    2 Jan 2020 4:56 PM | Zachary Edgar (Administrator)

    FAQs

    Continuing Education

    • How many continuing education hours are required during a reporting period?
    • How is contact hour defined?
    • How long is the reporting period?
    • Due date for CE requirements
    • Can CE credits be carried over into the next reporting period?
    • Are there any specific requirements for continuing education?
    • Are there any specific limitations on course subjects?
    • What types of activities can be used for the continuing education requirements?
    • Are there limitations on the types of courses that can be taken?
    • What type of approval is needed for the courses?
    • What type of courses or activities are not allowed?
    • What are the reporting requirements?
    • How long must continuing education records be retained?
    • Can I have my CE requirements waived?

    Scope of Practice

    • How is the practice of Physical Therapy defined in Florida?
    • Services specifically excluded from the scope of practice
    • Can PTs practice dry needling?
    • Can PTs administer topical medications?

    Electromyography

    • When a PT can perform electromyography
    • Education and supervised practice requirements

    Direct Access and Referrals 

    • Is a referral required to provide PT services?
    • Which providers are considered to be practitioners of record?
    • When does a PT have to refer a patient to a physician?

    Roles and Responsibilities 

    • Supervision Definitions
    • What are the overall responsibilities of the PT and PTA?
    • Which services can only be performed by a licensed physical therapist?
    • What are the responsibilities of the PT when delegating?

    Supervision of Assistants

    • Definition of a PTA
    • Responsibilities of the PTA
    • What type of supervision is required?
    • Accessibility of an offsite PT
    • Supervision of PTAs in a hospital setting

    Supervision of Aides

    • What can an aide do?
    • What is an aide expressly prohibited from doing?
    • What are the responsibilities of the PT when delegating to an aide?
    • Education and Training
    • What type of supervision is required?
    • Documentation

    Medical Records

    • What are the physical therapist’s documentation responsibilities?
    • How much can I charge a patient for copies of their records?
    • Medical records of PTs relocating or terminating their practice
    • Deceased Physical Therapists or Physical Therapist Assistants

    Temporary Permits

    • Who is eligible for a temporary permit?
    • What is required for the application?
    • What type of supervision is required for a temporary permit holder?
    • Duration of the permit

    Notifications and Postings

    • How can I use “Dr” in my title?
    • When does a PT have to notify the board of any information changes?

    Grounds for Discipline 

    • Unprofessional Conduct
    • Is there a law/rule against fee-splitting?

  • Texas Physical Therapy November 2019 Updates and Reorganization

    26 Nov 2019 4:23 PM | Zachary Edgar (Administrator)

    Continuing Education

    • How many continuing education hours are required during a reporting period?
    • How is credit hour defined?
    • How long is the reporting period?
    • Due Date
    • Can CE credits be carried over into the next reporting period?
    • Are there any specific requirements for continuing education?
    • What types of activities can be used for the continuing education requirements?
    • What type of approval is needed for the courses?
    • What type of courses or activities are not allowed?
    • What are the reporting requirements?
    • How long must continuing education records be retained?
    • Can I apply for a hardship waiver?
    • What happens if the board audits me?
    • CE Requirements for License Restoration

    Scope of Practice

    • How is the practice of Physical Therapy defined in Texas?
    • What is included in the practice of physical therapy?
    • Services specifically excluded from the scope of practice
    • Does Texas allow PTs to practice dry needling?
    • Does Texas allow PTs to practice electromyography?
    • Does Texas allow PTs to practice wound care?
    • Does Texas allow PTs to apply topical medicals?

    Direct Access and Referrals 

    • Is a referral required to provide PT services?
    • Exceptions to the referral requirement? Change September 2019
    • Limitation on the number of days that a PT may treat a patient without a referral
    • Patient disclosure
    • Emergencies
    • Additional Exemptions
    • Which providers can issue the referral?
    • How may the referral by transmitted?

    Telehealth

    • Requirements to provide PT through telehealth
    • Standard of Care
    • Informed Consent
    • Confidentiality
    • Role of a PTA

    Supervision and Delegation

    • Supervision Definitions
    • What are the professional responsibilities of the physical therapist?

    Assistants

    • Which services are PTAs allowed to practice?
    • Can a PTA screen patients?
    • Can a PTA modify the plan of care?
    • Are there specific services that PTAs are prohibited from practicing?
    • What type of supervision is required?
    • What are the assistant’s documentation responsibilities?
    • Does the supervising physical therapist need to co-sign documentation created by the PTA?
    • What is the ratio between supervising PTs and PTAs?
    • Required designation for assistants

    Aides

    • What can an aide do?
    • What is an aide expressly prohibited from doing?
    • What are the responsibilities of the PT when delegating to an aide?
    • What type of supervision is required?
    • What is the ratio between supervising PTs and aides?

    Documentation 

    • What must be included in the patient record?
    • What are the physical therapist’s documentation responsibilities?
    • Development and implementation of the plan of care
    • When is a reevaluation/reassessment required?
    • What must the reevaluation include?
    • Discharge Summary

    Facilities (Facility Registration no longer required) 

    Designations and Notifications

    • How can I use “Dr” in my title?
    • Are there any specific requirements for posting notifications or licenses?
    • Consumer Information Sign

    Temporary Permit

    • Who is eligible for a temporary permit?
    • What is required for the application?
    • What type of supervision is required for a temporary permit holder?
    • How long is the temporary permit valid for?

    License by Endorsement

    • Who is eligible for a license by endorsement?
    • What is required for the application?
    • Licensure for a Military Service Member
    • Provisional Licensure

    Out-of-State PTs and PTAs

    • Can I practice in Texas if I am licensed in another state?

    Retired or Inactive Status

    • Requirements for Initiation of Retired Status
    • Requirements for Renewal of Retired Status
    • Requirements for Reinstatement of Active Status
    • Designation
    • Requirements for Initiation of Inactive Status
    • Requirements for Renewal of Inactive Status
    • Requirements for Reinstatement of Active Status

    Unprofessional Conduct 

    • Practice in manner detrimental to public health and welfare
    • When am I obligated to report to the board?
    • Additional grounds for discipline
    • Gross negligence

    Educational Settings

    • Responsibilities of the PT
    • Consultations
    • Physician’s Referral
    • Evaluations

    Early Childhood Intervention Settings

    • Responsibilities of the PT
    • Referrals
    • Evaluations

  • Medicare Enrollment

    16 Sep 2019 1:17 PM | Zachary Edgar (Administrator)

    Occupational Therapists in Private Practice

    • Conditions for Enrollment
    • License Requirements
    • Education Outside the United States

    Physical Therapists in Private Practice

    • Conditions for Enrollment
    • License Requirements
    • Education Outside the United States

    Site Visits for PT Practices

    • Initial Application
    • Revalidation
    • New/Changed Location
    • Mixed PT and OT Groups
    • Physician Practice that Employs PTs
    • Multiple Locations
    • Home Based Practice
    • Scope of Site Visit

    Effective Enrollment Date and Retroactive Billing

    • Effective Date
    • Retroactive Billing

  • Medicare Plan of Care

    9 Sep 2019 5:36 PM | Zachary Edgar (Administrator)

    Physical or occupational therapy services must relate directly and specifically to a written treatment plan. The plan, (also known as a plan of care or plan of treatment) must be established before treatment is begun.

    The plan is established when it is developed (e.g., written or dictated). The signature and professional identity (e.g., MD, OTR/L) of the person who established the plan, and the date it was established must be recorded with the plan.

    Establishing the Plan of Care

    • Who may create the POC?
    • When treatment can begin under a POC
    • Multiple Plans of Care

    Contents of the Plan

    • Diagnosis
    • Long Term Goals (LTGs)
    • Type of Treatment
    • Multiple Disciplines
    • Amount of Treatment
    • Frequency of Treatment
    • Duration of Treatment

    Changing the Plan

    • Who may make “significant” changes to the POC?
    • What is considered a “significant change”?
    • What changes are considered “insignificant”?

    Certification and Re-certification of the Plan


  • Medicare Evaluations and Reevaluations for PT and OT

    9 Sep 2019 5:11 PM | Zachary Edgar (Administrator)

    Who Must Document the Evaluation?

    Only a clinician (PT or OT) may perform an initial examination, evaluation, re-evaluation and assessment or establish a diagnosis or a plan of care.

    When?

    The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.

    The time spent in evaluation shall not also be billed as treatment time. Evaluation minutes are untimed and are part of the total treatment minutes, but minutes of evaluation shall not be included in the minutes for timed codes reported in the treatment notes.

    Medical Necessity for an Initial Evaluation 

    Contents of an Evaluation

    • Diagnosis
    • Documentation Supporting Illness Severity or Complexity
    • Documentation Supporting Medical Care Prior to the Current Episode
    • Documentation Required to Indicate Beneficiary Health Related to Quality of Life
    • Documentation Required to Indicate Beneficiary Social Support
    • Documentation Required to Indicate Objective, Measurable Beneficiary Physical Function

    When the Evaluation is the Only Service Provided

    When the Evaluation Serves as the Plan of Care

    Additional Assessments

    Evaluations by Multiple Disciplines

    Billing Tips for the Evaluation

    Reevaluations

    • Who may Perform a Reevaluation?
    • Role of the Assistant
    • When can a Reevaluation be Performed?
    • Reimbursement
    • Content of the Reevaluation
    • Billing for a Reevaluation
    • Documentation

About Me

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.  

Learn More 

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