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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 Massachusetts Continuing Education Requirements for PTs and OTs

    10 May 2022 3:48 PM | Zachary Edgar (Administrator)

    Licensed physical therapists, physical therapist assistants, occupational therapists, and occupational therapy assistants are required, as a condition of license renewal, to complete a minimum of 24 points of Board recognized activities for maintaining continuing competence during the preceding biennial renewal period.

    See Massachusetts PT Continuing Education FAQs

    See Massachusetts OT Continuing education FAQs

  • New Medicare FAQs

    22 Apr 2022 2:13 PM | Zachary Edgar (Administrator)

    Criteria for Coverage

    • What conditions are required to furnish outpatient therapy for Medicare patients?
    • How do I demonstrate that the patient needs therapy services?
    • How do I show that the plan is periodically reviewed by a physician/NPP?
    • How can I document that the patient is or was under the care of a physician?

    Medical Necessity

    • When are services considered to be medical necessary under Medicare rules?
    • When are services considered to not be medically necessary?
    • What should be included in a POC for rehabilitative therapy?
    • What conditions are required in order for a maintenance program to be covered?
    • What factors demonstrate the need for therapy services?
    • Is a patient’s medical condition proof that the patient needs therapy?
    • How can medical necessity be demonstrated in documentation?
    • How can I continually show that therapy is medically necessary?

    Rehabilitation Programs

    • What should be included in a POC for rehabilitative therapy?
    • Is rehabilitative therapy appropriate if the patient has a chronic or terminal condition?
    • What should be included in the documentation?
    • When is rehabilitative therapy considered to be successful?
    • When is rehabilitative therapy not medically necessary?

    Maintenance Programs

    • How does Medicare define maintenance programs?
    • What conditions are required in order for a maintenance program to be covered?
    • When is a maintenance program not covered?
    • What needs to be documented when a maintenance program needs to be revised?

    Certifications

    • What does Medicare require for a certification?
    • Does Medicare require an order or referral?
    • Does Medicare require that the patient visit the physician?
    • Which providers can certify a POC?
    • Which providers cannot certify a POC?
    • When does the POC need to be certified?
    • Can the certification be done verbally?
    • What if I am having trouble getting the physician’s certification?
    • What if the physician fails to date the certification?
    • Is there a specific way the certification has to be formatted?
    • What happens if the certification is delayed?
    • When is recertification required?
    • What happens if payment is denied due to certification?

    Evaluations

    • Who can perform a therapy evaluation?
    • Can an assistant participate in an evaluation?
    • When does an evaluation need to be performed?
    • Can an evaluation and treatment be performed on the same visit?
    • What must be included in the evaluation?
    • When is an evaluation medically necessary?
    • Is an evaluation different from an assessment?
    • When is a screening more appropriate than an evaluation?
    • What if the evaluation is the only servicer provider during an episode of care?

    Reevaluations

    • Does Medicare require routine re-evaluations or reassessments?
    • When is a re-evaluation covered by Medicare?
    • Who can perform a re-evaluation?
    • What documentation must be included in a re-evaluation?
    • Is a re-evaluation the same as an assessment?
    • What are some examples of situations where a re-evaluation is appropriate?

    Plan of Care

    • Who can establish a therapy plan of care (POC)?
    • Who must sign the POC?
    • Can treatment begin before a POC has been established?
    • What must be included in the POC?
    • How do I document the diagnosis in the POC?
    • How should long-term goals be documented?
    • Does the POC need to contain short-term goals?
    • What does type of treatment mean?
    • What if a patient is being treated by more than on kind of therapy?
    • What does amount of treatment refer to?
    • What does frequency refer to?
    • What does duration refer to?
    • Can a patient be treated under two POCs?

    Treatment Notes

    • When are treatment notes required?
    • What if the note is not completed on the same day as treatment?
    • What is required to be included in the treatment note?
    • What information is optional but recommended?
    • What information is not required in the treatment note?
    • What are some tips for writing notes?
    • What need to be included if I use a grid form?
    • Who must sign the treatment note?
    • Does the supervisor’s signature need to be on the note?

    Progress Reports

    • Who must complete the progress report?
    • Who must sign the report?
    • When does the progress report need to be completed?
    • What happens if the patient is absent during the report period?
    • What happens if the report is delayed?
    • What does active participation mean?
    • Can the progress report be part of that day’s treatment note?
    • What must be included in the progress report?
    • How can the progress report be used to justify medical necessity?
    • Can an assistant participate in the report?

    Discharge Summary

    • Is a discharge summary required for every patient?
    • What if the patient just stops coming to therapy?
    • What is required on the discharge summary?
    • What if a progress report was done close to the anticipated discharge date?


  • Ohio Physical Therapy FAQs

    30 Mar 2022 4:14 PM | Zachary Edgar (Administrator)

    Ohio Physical Therapy FAQs have been posted.

  • Employment section added to every state

    7 Mar 2022 2:40 PM | Zachary Edgar (Administrator)

    You can now submit employment listings for therapists, assistants, aides, or office staff, $50 per listing; member can post three free listings each month.

    Therapists and assistants can also submit resumes so we can match you with open positions.  

    Email us a info@therapycomply.com for more information. 

  • Significant Updates to our HIPAA Page

    3 Mar 2022 11:53 AM | Zachary Edgar (Administrator)

    Welcome to our HIPAA section.  Members can access high quality guides, FAQs, and policies and procedures on every aspect of HIPAA.  If you need more direct assistance, please visit our consultations page.

    HIPAA Package - A collection of legally required notices, forms, policies and procedures that can be used by small and medium healthcare providers to supplement their existing material. (Available for Yearly Members).

    Upcoming Free Webinar: HIPAA Security Assessments and Risk Mitigation

    March 9th at 12:00 PM - 1:00 PM CST

    March 10th at 12:00 PM - 1:00 PM EST

    HIPAA FAQs

    • Does HIPAA apply to my practice?
    • What information protected under HIPAA?
    • What is a covered entity?
    • What is a business associate?
    • What is the Privacy Rule?
    • What is the Security Rule?

    The Privacy Rule

    Business Associates

    Cyber Security

    The Security Rule

    • Who does the Security Rule apply to?
    • “Required” and “Addressable” Specifications
    • Policies and Procedures
    • Administrative Safeguards
    • Physical Safeguards
    • Technical Safeguards
    • Organizational Requirements

    Breach Notifications


  • New Recorded Webinars for Yearly Members

    5 Feb 2022 4:27 PM | Zachary Edgar (Administrator)

    Recorded Webinars for Yearly Members 

    Yearly members can access all recently recorded webinars here.  CE credit is available for many of these courses, please contact Zachary at zedgar@med-comply.com.  


  • Changes to the Medicare Documentation Section

    31 Jan 2022 2:48 PM | Zachary Edgar (Administrator)

    Documentation for Therapy Services

    Therapy Comply's Medicare documentation guides for physical, occupational, and speech therapy.  

    Sample Audit Form - Can be used to audit outpatient therapy documentation. 

    General Documentation Requirements

    • Document Requirements
    • The Patient is under the Care of a Physician/NPP
    • Services Require the Skills of a Therapist
    • Services are of Appropriate Type, Frequency, Intensity and Duration 
    • Needs of the Patient
    • Dictated Documentation
    • Dates for Documentation

    Evaluations

    • When it is Appropriate for an Initial Evaluation
    • Contents of an Evaluation
    • When the Evaluation is the Only Service Provided
    • When the Evaluation Serves as the Plan of Care
    • Additional Assessments
    • Evaluations by Multiple Disciplines

    Plan of Care

    • Establishing the Plan of Care
    • Elements of the Plan of Care
    • Modifying the Plan of Care

    Certification and Re-certification of the Treatment Plan

    • What does it mean to have the plan of care certified?
    • Do I need an order/prescription/referral from a physician/NPP?
    • When does the POC need to be certified?
    • Is the initial treatment date when I began treating the patient or when I performed the evaluation?
    • How long do certifications last?
    • What happens if I can’t get the plan certified within ninety (90) days?
    • Do I need to submit additional evidence to justify the delay?
    • Who must certify the POC?
    • Which practitioners are not allowed to certify a plan of care?
    • Can I have the physician/NPP sign a document other than the POC?
    • Are verbal certifications acceptable?
    • When does the POC need to be recertified?
    • What happens if the recertification is delayed?
    • What happens if my claim is denied due to certification issues?

    Progress Reports 

    • Timing of the Progress Report
    • Content of the Progress Report
    • Therapist’s Participation in the Report
    • Assistant’s Participation in the Report

    Treatment Notes

    • Required Elements
    • Optional Elements
    • Examples for Specific Services
    • Making Changes to the Note
    • Signature on the Note
    • Identification of the Supervisor

    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

    Discharge Summary

    • What is Required in the Discharge Note?
    • Unanticipated Discharge
    • Optional Information

      Medicare Signature Requirements

      • Which outpatient therapy documentation requires and signature and who must sign?
      • What is required for a valid signature?
      • What if I use a scribe when documenting medical record entries?
      • How are orders treated differently than other medical documentation?
      • What should I do if I did not sign an order or medical record?
      • What if I signed the order or progress note but my signature is not legible?
      • What is a signature log?
      • What if I do not have a signature log in place?
      • Am I able to attest to my signature?
      • Do my signatures need to be dated?


    • North Carolina Medicaid Guidelines

      28 Jan 2022 3:23 PM | Zachary Edgar (Administrator)

      North Carolina Medicaid Outpatient Therapy 

      Guidelines for North Carolina's Medicaid coverage of physical, occupational and speech therapy services.  Including coverage, limitations, prescription requirements, prior authorization and documentation.  If the client is enrolled in a managed care plan some of the rules may be different.  If you need additional assistance please email us at info@therapycomply.com.

      Eligible Providers

      • Eligible Providers
      • Settings
      • Assistants

      Documentation 

      • Documentation Requirements
      • Evaluations
      • Re-evaluations
      • Treatment Plan
      • Discharge
      • Follow-Up

      Medical Necessity for SLP Services

      • Oral Phase, Pharyngeal Phase, or Oropharyngeal Phase Dysphagia
      • English Language Proficiency
      • Language Impairment Classifications Infant/Toddler: Medicaid Beneficiary Birth to 3 Years:
      • Language Impairment Classifications: Medicaid Beneficiary 3 – 5 Years of Age
      • Language Impairment Classifications: Medicaid Beneficiary 5 through 20 Years of Age and NCHC Beneficiary 6 through 18 Years of Age
      • Articulation/Phonology Impairment Classifications : Medicaid Beneficiary birth through 20 Years of Age and NCHC Beneficiaries 6 through 18 Years of Age
      • Articulation Treatment Goals Based on Age of Acquisition
      • Phonology Treatment Goals Based on Age of Acquisition of Phonological Rules
      • Eligibility Guidelines for Stuttering
      • Differential Diagnosis for Stuttering
      • Augmentative and Alternative Communication (AAC) Devices
      • Audiology Therapy (Aural Rehabilitation)
      • Evaluation for Central Auditory Processing Disorders (CAPD)

      Prescription Requirement

      • Who may order therapy services?
      • When does the order need to be signed?
      • How long are verbal/written orders valid for?

      Prior Approval

      • Beneficiaries under the Age of 21 Years
      • Visit Limitations Beneficiaries 21 Years of Age and Older
      • Medical Necessity Visit Guidelines for Beneficiaries Under 21 Years of Age

      Treatment 

      • Medical Necessity
      • Co-Treatment


    • California Medicaid Outpatient Therapy Guidelines

      28 Jan 2022 10:17 AM | Zachary Edgar (Administrator)

      Guidelines for California's Medicaid coverage of physical, occupational and speech therapy services.  Including coverage, limitations, prescription requirements, prior authorization and documentation.  If the client is enrolled in a managed care plan some of the rules may be different.  If you need additional assistance please email us at info@therapycomply.com.

      Physical Therapy

      • Eligible Providers
      • Prescription Requirements
      • Covered Services
      • Prior Authorization
      • Claim Information

      PT Codes and Rates

      Speech Therapy

      • Eligible Providers
      • Coverage
      • Written Referral Requirements
      • Initial and Six-Month Evaluations
      • Required Professional Experience Services

      SLP Codes and Rates

      Occupational Therapy

      • Eligible Providers
      • Limitations
      • Prescription Requirement
      • Initial and Six-Month Evaluations
      • Claims

      OT Codes and Rates


    • Compliance Policies and Procedures

      19 Jan 2022 11:04 AM | Zachary Edgar (Administrator)

      We have recently added a number of new sample policies and procedures that can be easily adapted to any therapy practice.

      Visit at our Compliance Page. 

    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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    Join today as a yearly or monthly 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.

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