Upcoming Webinars

Site Updates

Disclaimer

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.

Menu
Log in
Forgot password


Search
Log in
Forgot password

Site Updates

  • Plan of Care FAQs

    7 Feb 2023 10:49 AM | Zachary Edgar (Administrator)

    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


  • Medicare Evaluations/Reevaluations FAQs

    6 Feb 2023 10:48 AM | Zachary Edgar (Administrator)

    See our Medicare Evaluations and Medicare Re-evaluations sections for more detailed guidance.

    Who can perform a therapy evaluation?

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

    A clinician means either a physician or a physical, occupational, or speech therapist.

    When does an evaluation need to be performed?

    An evaluation must be completed prior to beginning of treatment.

    Can an evaluation and treatment be performed on the same visit?

    Yes. Once the evaluation has been completed, the therapist may start treatment.

    What must be included in the evaluation?

    A diagnosis (where allowed by state and local law) and description of the specific problem(s) to be evaluated and/or treated.

    Results of one of the following four measurement instruments are recommended, but not required:

    • National Outcomes Measurement System (NOMS) by the American Speech-Language Hearing Association
    • Patient Inquiry by Focus On Therapeutic Outcomes, Inc. (FOTO)
    • Activity Measure – Post Acute Care (AM-PAC)
    • OPTIMAL by Cedaron through the American Physical Therapy Association

    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.

    References

    Medicare Benefit Policy Manual Ch. 15 – Covered Medical and Other Health Services §220.3

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

    Billing and Coding: Therapy Evaluation, Re-Evaluation and Formal Testing: A52773

    Outpatient Physical and Occupational Therapy Services: L34049


  • Medicare Certification FAQs

    3 Feb 2023 10:46 AM | Zachary Edgar (Administrator)

    See our Medicare Certification/Recertification section for more guidance.

    What does Medicare require for a certification?

    Certification requires a dated signature on the plan of care or some other document that indicates approval of the plan of care.

    The physician’s/NPP’s certification of the plan (with or without an order) satisfies all of the certification requirements for the duration of the plan of care, or ninety (90) calendar days from the date of the initial treatment, whichever is less. The initial treatment includes the evaluation that resulted in the plan.

    When does the POC need to be certified?

    The provider or supplier (e.g., facility, physician/NPP, or therapist) should obtain certification as soon as possible after the plan of care is established, unless the requirements of delayed certification are met. “As soon as possible” means that the physician/NPP shall certify the initial plan as soon as it is obtained, or within thirty (30) days of the initial therapy treatment.

    Timely certification of the initial plan is met when physician/NPP certification of the plan is documented, by signature or verbal order, and dated in the thirty (30) days following the first day of treatment (including evaluation).

    Can the certification be done verbally?

    If the order to certify is verbal, it must be followed within 14 days by a signature to be timely. A dated notation of the order to certify the plan should be made in the patient’s medical record.

    When is recertification required?

    Recertifications that document the need for continued or modified therapy should be signed whenever the need for a significant modification of the plan becomes evident, or at least every ninety (90) days after initiation of treatment under that plan, unless they are delayed.

    References

    Medicare Benefit Policy Manual Ch. 15 – Covered Medical and Other Health Services § 220.1.3

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


  • Medicare Orders/Referrals FAQs

    2 Feb 2023 10:45 AM | Zachary Edgar (Administrator)

    Does Medicare require an order or referral?

    No. Although there is no Medicare requirement for an order, an order provides evidence that the patient both needs therapy services and is under the care of a physician. The certification requirements are met when the physician certifies the plan of care, this means the physician/NPP has signed and dated the plan of care.

    If the signed order includes a plan of care, no further certification of the plan is required. Payment is dependent on the certification of the plan of care rather than the order, but the use of an order is prudent to determine that a physician is involved in care and available to certify the plan.

    When does the POC have to signed by the physician/NPP?

    Timely certification of the initial plan is met when physician/NPP certification of the plan is documented, by signature or verbal order, and dated in the 30 days following the first day of treatment (including evaluation). If the order to certify is verbal, it must be followed within 14 days by a signature to be timely. A dated notation of the order to certify the plan should be made in the patient’s medical record.  

    Does Medicare require that the patient visit the physician?

    Medicare does not require a visit unless the National Coverage Determination (NCD) for a particular treatment requires it (e.g., see Pub. 100- 03, §270.1 - Electrical Stimulation (ES) and Electromagnetic Therapy for the Treatment of Wounds).

    Which providers can certify a POC?

    Physicians and non-physician practitioners such as nurse practitioners and physician assistants.

    Certifications and recertifications by doctors of podiatric medicine must be consistent with the scope of the professional services provided by a doctor of podiatric medicine as authorized by applicable state law. Optometrists may order and certify only low vision services.

    Which providers cannot certify a POC?

    Chiropractors may not certify or recertify plans of care for therapy services.

    The CORF services benefit does not recognize an NPP for orders and certification.

    References

    Medicare Benefit Policy Manual Ch. 15 – Covered Medical and Other Health Services § 220.1.3

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


  • Updated Oklahoma PT FAQs

    1 Feb 2023 1:54 PM | Zachary Edgar (Administrator)

    Added: Scope of practice, continuing education, telehealth, referrals, and ethical/unprofessional conduct.

    Oklahoma PT FAQs

  • Criteria for Coverage FAQs

    1 Feb 2023 10:44 AM | Zachary Edgar (Administrator)

    See our Outpatient Therapy section for more information on medical necessity.

    What conditions are required to furnish outpatient therapy for Medicare patients?

    The following conditions apply:

    • Services are or were required because the individual needed therapy services;
    • A plan for furnishing such services has been established by a physician/NPP or by the therapist providing such services and is periodically reviewed by a physician/NPP;
    • Services are or were furnished while the individual is or was under the care of a physician; and
    • Claims submitted for outpatient PT, OT, and SLP services must contain the National Provider (NPI) of the certifying physician identified for a PT, OT, and SLP plan of care.

    In certifying an outpatient plan of care for therapy a physician/NPP is certifying that the above conditions are met.

    How do I demonstrate that the patient needs therapy services?

    The evaluation must include the patient’s particular medical condition that requires skilled therapy.  The plan of care must show that the services are at a level of complexity and sophistication, or the condition of the patient shall be such that the services required can be safely and effectively performed only by a therapist, or in the case of physical therapy and occupational therapy by or under the supervision of a therapist.

    See Medical Necessity for more information.

    How do I show that the plan is periodically reviewed by a physician/NPP?

    Medicare requires that the plan of care be recertified by the physician/NPP every 90 days.  Recertification is also required if the long term goals in the plan of care are changed.

    See Certification and Recertification for more information.

    How can I document that the patient is or was under the care of a physician?

    Specific documentation that demonstrates that the patient is/was under the care of a physician is not necessary.  Physician certification of the plan of care is the only requirement.   

    Unless there is reason to believe the plan was not signed appropriately, or it is not timely, no further evidence that the patient was under the care of a physician/NPP and that the patient needed the care is required.

    References

    Medicare Benefit Policy Manual Ch. 15 § 220.1

    Medicare Benefit Policy Manual Ch. 15 § 220.1.1


  • Added new OSHA and safety policies and procedures

    15 Dec 2022 11:52 AM | Zachary Edgar (Administrator)

    Employee safety policies and procedures specific to therapy practices.  Members have full access to the guidance documents below and can email us with questions regarding workplace safety and practice specific policies. 

    OSHA Material

    • Blood Bourne Pathogens P&P (Required for Dry Needling)
    • Work-Related Musculoskeletal Disorders
    • Equipment Hazards
    • Slips/Trips/Falls

    Therapy Safety Policies

    • Infection Control Guidelines
    • Universal Precautions
    • Fingernails
    • General Safety Policies
    • General Medical Therapy Equipment
    • Equipment Maintenance
    • Equipment Cleaning/Sterilization
    • Electrically Energized Equipment
    • Patient Transport Equipment
    • Bandaging and Taping
    • Cold Packs
    • Contrast Baths
    • Electrical Muscle Stimulation
    • Heat Packs
    • Iontophoresis
    • Paraffin Bath
    • Skin Care Protocol
    • Transcutaneous Electrical Nerve Stimulation
    • Ultrasound Contact Technique via Gel or Gel Pak
    • Ultrasound Underwater Technique


  • New Guides Added to Medicare Billing and Coding

    23 Nov 2022 3:34 PM | Zachary Edgar (Administrator)


  • Medicare Coverage of Nerve Conduction and Electromyography

    31 Oct 2022 1:59 PM | Zachary Edgar (Administrator)

    Medicare Coverage of Nerve Conduction and Electromyography

  • Medicare Coverage of Biofeedback

    31 Oct 2022 1:57 PM | Zachary Edgar (Administrator)

    Added guidance for Medicare coverage of Biofeedback. 

About Us

Therapy Comply is a healthcare compliance firm that seeks to bring high quality web-based compliance guidance and one-on-one consulting services to small and medium size physical, occupational, and speech therapy practices.

Learn More 

Join Us

Join today as either a monthly or a yearly member and enjoy full access to the site and a significant discount to our live and recorded webinars.  Members also have access to compliance and billing support.

Join Today 

Find Us


Powered by Wild Apricot Membership Software