CarePoint Therapy Management Blog

The Centers for Medicare & Medicaid Services (“CMS”) released Transmittal 2457 dated April 27, 2012.  This transmittal creates a “manual medical review process” for therapy services that exceed $3,700 annually as of October 1, 2012.  No details were provided on how CMS will manage the manual medical review process.  Also, providers will be required to report the National Provider Identifier (“NPI”) of the physician or non-physician practitioner reviewing the therapy plan of care on the beneficiary’s UB-04 claim form.  Click here for the complete text of CMS Transmittal 2457.

Residents of skilled nursing facilities will experience a decline from their best level of function.  This is an unavoidable result of the normal aging process.  Therapists should not “get used to” seeing residents decline.  Rather, they should ask themselves, “Can I make this person better, can I reduce the burden of care they place on the facility, and can I increase their ability to participate more fully in daily life?”

A VP of Therapy Operations in Arkansas writes …..
“I reviewed the recent SNF PPS Clarifications Memo V1.1, dated March 2012 and would like to know how to best manage this issue.  My greatest concern is selecting the correct ARD and thus preventing a lower “default” per diem reimbursement for Medicare Part A patients.”

Therapists are responsible for compliance with CMS rules pertaining to how different types of therapy minutes are provided during a treatment session.  If these rules are not applied correctly, the compliance errors that occur will result in denials.  These errors are costly both in terms of lost revenue and the time needed to research, re-bill, and recover that lost revenue.  The three different types of therapy minutes are individual, concurrent, and group therapy minutes.  Simple and effective tools are required to alert therapists when therapy minutes provided are not in compliance with CMS’s rules.  Better still, quick and easy ways that correct these errors before claims are submitted or RUG’s levels and ARD’s are selected will prevent denials and maximize reimbursements.

CMS has issued the following guidelines for End of Therapy OMRA’s.
“An End of Therapy (EOT) OMRA would require a change in the RUG’s level for selected days.  An EOT OMRA is required if there are 3 missed days with no therapy from any discipline.  For the EOT OMRA followed by a SOT OMRA, the 3 or more missed days are billed at the NC RUG’s level.”  

Therapists are responsible for compliance with the Correcting Coding Initiative.  These compliance rules have complex guidelines on how “therapists” should apply modifiers to CPT codes provided.  These rules are especially complex when treatments are provided by more than one discipline or for other special conditions.  If modifiers are missing when these conditions are present, then the charges will be denied.  These errors are costly both in terms of lost revenue and the time needed to research, re-bill, and recover that lost revenue.

CarePoint therapy management software strives for complete regulatory and compliance accuracy. Our system requires 5 calendar days of therapy in the last 7 days in order to achieve a RUG’s Level Medium (RM) in accordance with the PPS regulations of 1998. We understand all the discipline requirements for each RUG’s level.

CarePoint’s Clinical Staff Responds …..

Author: Mary L. Gennerman, OTR/L - Director of Clinical Services
Licensed therapists, typically an RPT or OTR, must be actively involved in a patient’s care at least once every 10^th visit in order to verify that the therapy provided is consistent with the plan of care, to modify the plan of care if necessary, and to ensure that ongoing therapy is properly supervised.  Reliance on therapy assistants, typically LPTA’s or COTA’s, to treat patients for 10 visits or more will result in claims denials.  Providers often question whether the Required 10^th Therapy Visit Rule applies to Medicare Part B patients only or to both Medicare Part A and B patients alike.