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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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  • California Speech Therapy Scope of Practice

    1 Oct 2021 4:56 PM | Zachary Edgar (Administrator)

    How does California define the practice of speech-language pathology?

    The practice of speech-language pathology means all of the following:

    • The application of principles, methods, instrumental procedures, and non-instrumental procedures for measurement, testing, screening, evaluation, identification, prediction, and counseling related to the development and disorders of speech, voice, language, or swallowing.
    • The application of principles and methods for preventing, planning, directing, conducting, and supervising programs for habilitating, rehabilitating, ameliorating, managing, or modifying disorders of speech, voice, language, or swallowing in individuals or groups of individuals.
    • Conducting hearing screenings.
    • Performing suctioning in connection with the scope of practice, after compliance with a medical facility’s training protocols on suctioning procedures.

    Any observation of an abnormality shall be referred to a physician and surgeon.

    What is specifically excluded from the practice?

    N/A

    Flexible Fiber Optic Nasendoscopic Procedure

    A licensed speech-language pathologist shall not perform a flexible fiber optic nasendoscopic procedure unless he or she has received written verification from an otolaryngologist certified by the American Board of Otolaryngology that the speech-language pathologist has performed a minimum of twenty-five (25) flexible fiber optic nasendoscopic procedures and is competent to perform these procedures. The speech-language pathologist shall have this written verification on file and readily available for inspection upon request by the board.

    A speech-language pathologist shall pass a flexible fiber optic nasendoscopic instrument only under the direct authorization of an otolaryngologist certified by the American Board of Otolaryngology and the supervision of a physician and surgeon.

    A licensed speech-language pathologist shall only perform flexible endoscopic procedures in a setting that requires the facility to have protocols for emergency medical backup procedures, including a physician and surgeon or other appropriate medical professionals being readily available.

    Reference

    Cal. Bus. and Prof. Code § 2530.2

  • California Occupational Therapy Scope of Practice

    1 Oct 2021 4:53 PM | Zachary Edgar (Administrator)

    How is occupational therapy defined in California?

    “Occupational therapy” means the therapeutic use of purposeful and meaningful goal-directed activities (occupations) with individuals, groups, populations, or organizations, to support participation, performance, and function in roles and situations in home, school, workplace, community, and other settings.

    Occupational therapy services are provided for habilitation, rehabilitation, and the promotion of health and wellness for clients with disability- and nondisability-related needs or to those who have, or are at risk of developing, health conditions that limit activity or cause participation restrictions. Occupational therapy services encompass occupational therapy assessment, treatment, education, and consultation.

    Occupational therapy addresses the physical, cognitive, psychosocial, sensory-perception and other aspects of performance in a variety of contexts and environments to support engagement in occupations that affect physical and mental health, well-being, and quality of life.

    What is included in the practice of occupational therapy?

    Occupational therapy techniques that are used for treatment involve:

    • Teaching activities of daily living (excluding speech-language skills);
    • Designing or fabricating orthotic devices, and applying or training in the use of assistive technology or orthotic and prosthetic devices (excluding gait training).

    Occupational therapy consultation provides expert advice to enhance function and quality of life. Consultation or treatment may involve modification of tasks or environments to allow an individual to achieve maximum independence. Services are provided individually, in groups, or populations.

    Occupational therapy treatment is focused on developing, improving, or restoring functional daily living skills, compensating for and preventing dysfunction, or minimizing disability. Through engagement in everyday activities, occupational therapy promotes mental health by supporting occupational performance in people with, or at risk of experiencing, a range of physical and mental health disorders.

    What is specifically excluded from the practice?

    N/A

    Are there any special trainings or requirements?

    California OT Hand Therapy

    California OT Physical Agent Modalities

    California OT Topical Medications

    California OT Swallowing Assessment, Evaluation and Training

    Reference

    Cal. Bus. and Prof. Code § 2570.2

  • California Physical Therapy Scope of Practice

    1 Oct 2021 4:52 PM | Zachary Edgar (Administrator)

    How is physical therapy defined in California?

    Physical therapy means the art and science of physical or corrective rehabilitation or of physical or corrective treatment of any bodily or mental condition of any person by the use of the physical, chemical, and other properties of heat, light, water, electricity, sound, massage, and active, passive, and resistive exercise, and shall include physical therapy evaluation, treatment planning, instruction and consultative services.

    What is included in the practice of physical therapy?

    The practice of physical therapy includes the promotion and maintenance of physical fitness to enhance the bodily movement related health and wellness of individuals through the use of physical therapy interventions.

    What is specifically excluded from the practice?

    The use of roentgen rays and radioactive materials, for diagnostic and therapeutic purposes, and the use of electricity for surgical purposes, including cauterization, are not authorized under the term “physical therapy”, and a physical therapy license does not authorize the diagnosis of disease.

    Are there any special trainings required?

    See Electromyography

    See Topical Medications

    Board Statements on the Scope of Practice

    Can PTs practice wound debridement?

    Debridement is performed by the use of sharp instruments including, but not limited to, scalpel, scissors, forceps or tweezers. Debridement of devitalized tissue is not to be confused with surgical debridement, which is to be performed by a physician and includes the removal of both devitalized and vitalized tissues. Physical therapists by education and training should be able to differentiate between necrotic, nonviable tissue, and viable tissues.

    It is the official position of the Physical Therapy Board of California that, with appropriate training, physical therapists can perform debridement of nonviable tissue. Furthermore, it is the position of the Board that physical therapists may utilize sharp instruments such as scalpels, scissors, forceps, tweezers and other appropriate instruments to perform debridement.

    Does California allow PTs to remove staples and sutures?

    The removal of staples is a non-invasive procedure, which would ordinarily come under the heading of nursing services and is not normally associated with the practice of physical therapy; however, physical therapists may provide any non-invasive physical rehabilitation procedure they have been adequately trained to perform. Should a facility elect to train physical therapists to do staple removal, the facility would need a written protocol to be included in their policies and procedures manual, and to be used in the training of each physical therapist who will perform this procedure.

    The training protocol must be sufficient to ensure the facility's patients that the procedure is being done in a safe and efficient manner by personnel who are trained specifically to remove staples. The training should also include procedures for problem situations resulting from staple removal, and for notification of proper medical personnel.

    The removal of sutures would fall under the same category as the removal of staples as indicated above.

    Reference

    Cal. Bus. and Prof. Code §2620

    California Physical Therapy Board Position Statements

  • Overhaul of our Medicare Appeals Section

    31 Aug 2021 1:52 PM | Zachary Edgar (Administrator)

    Medicare Appeals

    Denials by Medicare are on the rise.  Congress and the Office of Inspector General have both called for increased scrutiny over Part A and B Medicare claims.  Reduced payments to Medicare Advantage Plans have caused the plans to take a more hardline approach to claims approvals and denials.  Providers’ main tool to combat these denials is the appeals process.   If you are thinking about filing an appeal and need assistance, please contact us at zedgar@med-comply.com.

    Levels of Appeals and Time Limits for Filing

    Good Cause for Late Filing

    Decisions Subject to Appeal

    Who may File an Appeal Representatives

    Appointing the Representative 

    Reopenings

    Level 1: Redetermination Level 2: Reconsideration Level 3: Administrative Law Judge (ALJ) Hearing

    Level 4: Appeals Council Review

    Level 5: Judicial Review


  • Texas Physical Therapy FAQs

    13 Jul 2021 12:05 PM | Zachary Edgar (Administrator)

    Scope of Practice

    • How is physical therapy defined in Texas?
    • What is included in the practice of physical therapy?
    • What is specifically excluded from the practice?
    • Are there any special trainings or requirements?

    Direct Access and Referrals 

    • When can a PT treat a patient without a referral?
    • Patient consent to be treated without a referral
    • Which providers can issue the referral?
    • Methods of referral

    Supervision and Delegation

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

    Assistants

    • What services are PTAs allowed to perform?
    • Are there specific services that PTAs are prohibited from practicing?
    • What type of supervision is required?
    • Does the supervising physical therapist need to co-sign documentation created by the PTA?
    • Is a reevaluation or reassessment required?
    • 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

    Documentation 

    • What must be included in the patient record?
    • What are the PT’s documentation responsibilities?
    • When is a reevaluation/reassessment required?
    • Discharge Summary

    Designations and Notifications

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

    Continuing Education

    • How many continuing education hours are required during a reporting period?
    • 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?
    • What type of approval is needed for the courses?
    • What are the reporting requirements?
    • Waivers and audits 

    Telehealth

    • Licensure
    • Technology
    • Standard of Care
    • Informed Consent
    • Confidentiality

    Graduate and Student Practice

    • Can students practice in a clinical setting?
    • What kind of supervision is required for student PTs and PTAs?
    • How must students identify themselves?
    • What type of license/permit must new graduates receive before practicing?
    • Eligibility
    • What kind of supervision is required?
    • Duration of the temporary license

    Out-of-State PTs and PTAs

    • Situations where an out-of-state PT/PTA can practice in Texas

    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

    Educational and Early Intervention Settings

    • Services which may require a physician’s referral
    • Evaluation and reevaluation
    • Role of the PT in Early Childhood Intervention settings
    • Services which require a referral
    • Evaluation and reevaluation

    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


  • Medicare Advanced Notification of Noncoverage (ABN) Updated

    24 Jun 2021 2:02 PM | Zachary Edgar (Administrator)

    An Advanced Beneficiary Notice of Noncoverage (ABN) is a form given to the Medicare patient before performing healthcare services that the provider knows are not covered or that the provider thinks may not be covered by the Medicare program.   The form is used to serve as notice to the patient that 1) the service is not covered and 2) that they will be liable to pay for the service. 

    When it is Mandatory to Issue an ABN?

    When it is Voluntary to Issue an ABN?

    Triggering Events (When to give the patient the ABN)

    • Initiations
    • Reductions
    • Terminations
    Issuing the ABN

    ABN Form and Instructions

    • Header
    • Body
    • Options
    • Additional Information
    • Signature Box

    ABN Preparation Requirements

    • Language Choice
    • Effective Versions
    • Number of Copies
    • Reproduction
    • Length and Size of Page
    • Contrast of Paper and Print
    • Font
    • Customization
    • Modification
    • Retention Requirements

    ABN Notice and Delivery

    • Proper Notice Requirements
    • Readability Requirements
    • Specificity, Delivery, and Receipt
    • Defective Notice
    • Timeliness
    • Effective Delivery
    • Telephone Notice
    • Capable Recipient
    • Authorized Representatives

    Routine Notice Prohibitions and Exceptions

    • Generic ABNs
    • Blanket ABNs
    • Signed Blank ABNs
    • Exceptions
    ABN Modifiers


  • Florida Occupational Therapy Additions

    21 Jun 2021 4:38 PM | Zachary Edgar (Administrator)

    Florida Occupational Therapy

    Continuing Education

    • How many continuing education hours are required during a reporting period?
    • How is credit hour defined?
    • How long is the reporting period?
    • 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?
    • How long must continuing education records be retained?

    Scope of Practice

    • How is occupational therapy defined in Florida?
    • What is included in the practice of occupational therapy?
    • What is specifically excluded from the practice?
    • Are there any special trainings or requirements?

    Electrical Stimulation Devices

    • Required Training
    • Supervised Treatment Sessions
    • Minimum Competency Levels

    Ultrasound Devices

    • Required Training
    • Supervised Treatment Sessions
    • Minimum Competency Levels

    Neurofeedback Devices

    • Required Training
    • Supervised Treatment Sessions
    • Minimum Competency Levels

    Assistants

    • What type of supervision is required?
    • Does the supervising OT need to be present?
    • Does the supervising occupational therapist need to co-sign documentation created by the OTA?
    • What is the ratio between supervising OTs and OTAs?

    Aides

    • How is an aide defined?
    • What can an aide do?
    • What is an aide expressly prohibited from doing?
    • What are the responsibilities of the OT when delegating to an aide?
    • What type of supervision is required?
    • What is the ratio between supervising OTs and aides?
    • Required designation for aides

    Students 

    • Can students practice in a clinical setting?
    • How must students identify themselves?

    Unprofessional Conduct 

    • Reporting Obligations
    • Prohibitions
    • Fee Splitting


  • Maryland Occupational Therapy Additions

    20 Jun 2021 3:31 PM | Zachary Edgar (Administrator)

    Continuing Education 

    • How many continuing education hours are required during a reporting period?
    • 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?
    • What type of approval is needed for the courses?
    • What are the reporting requirements?
    • Waivers and audits 

    Scope of Practice

    • How is the practice of Occupational Therapy defined in Maryland?
    • What services are included in the scope of practice?
    • Services specifically excluded from the scope of practice
    • Are there any specific procedures or modalities regulated by the board?

    Physical Agent Modalities

    • Definitions
    • Standards of Competence for Electrical Modalities
    • Didactic Education
    • Clinical Requirements
    • Documentation of Education
    • Treatment Plan Guidelines for Physical Agent Modalities
    • Superficial Physical Agent Modalities

  • HIPAA Updates and Page Cleanup

    10 Jun 2021 2:49 PM | Zachary Edgar (Administrator)

    HIPAA Guides and FAQs

    HIPAA Basics

    The Security Rule

    Breach Notifications

    The Privacy Rule

    Business Associates 

    Sample Forms and Agreements - A collection of notices, forms, policies and procedures that can be used by small and medium healthcare providers to supplement their existing material.

  • June 2021 NCCI Updated Have Been Added

    7 Jun 2021 1:37 PM | Zachary Edgar (Administrator)

    See our NCCI page for more information. 

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