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Today's post comes from Tom Ambury, PT and compliance officer at PT Compliance Group, and WebPT cofounder and COO Heidi Jannenga, PT, MPT, ATC/L.

One of the most frequently asked questions in the PT billing space is: "Our state practice act allows licensed PTAs to treat without direct onsite supervision. I understand that PTAs can’t bill under their own National Provider Identifier (NPI) and license, so how do I bill for my PTA’s services?"

The answer: Don’t confuse state licensure laws with billing rules.

Per Medicare rule: 42 C.F.R. §410.26(b)(1)-(7); and CMS Medicare Benefit Policy Manual, Pub. 100-4, Ch. 15, §60.1 - §60.5, in order to bill for outpatient services provided by a PTA in a non-institutional setting, the claim must meet the following conditions:

  1. The supervising therapist performs the evaluation and establishes the plan of care.
  2. The services the PTA provides are medically necessary.
  3. The supervising therapist provides direct onsite supervision (i.e., he or she can be in the same building but not necessarily in the same room).
  4. The supervising therapist must be immediately available to intervene. (i.e., he or she cannot be doing something that is uninterruptable.) 
  5. The supervising therapist must have active ongoing involvement in the management and control of the patient's condition.
  6. If the patient presents with a new condition, the supervising therapist must see the patient.
  7. The PTA providing the service under the direct onsite supervision of the therapist must be an employee or an independent contractor of the practice. 

The above information applies to Medicare specifically. Although we are unable to find an exact reference for commercial insurance carriers, many commercial insurance contracts have language that states: “follows billing rules defined by Medicare.” In case law, there are numerous examples of prosecution for violating these billing rules for Medicare, so the most important take-away is to proceed at your own risk. If your state law allows licensed PTAs to treat without direct onsite supervision, understand that Medicare (and most likely many commercial insurance companies) do not allow for this. You cannot receive reimbursement for services that do not meet the conditions listed above. Ultimately, you must supervise your PTAs if you want to get paid, and for both Medicare and commercial insurances, make absolutely sure you document correctly and in detail. 

Here are four tips to help you ensure your documentation demonstrates that you’ve met the necessary, aforementioned conditions:

  1. Include language that affirms you reviewed your plan of care with the PTA providing the service under your direction. 
  2. Document regular meetings with the PTA where you review the patient's progress. 
  3. Indicate when the treatment has advanced to the next more complex or sophisticated task. 
  4. Cosign the daily note, but also have the PTA document that he or she “provided services under the direct supervision of (name of the supervising therapist).”

How do I implement this using WebPT Billing or one of WebPT’s billing integration partners? 

The most important thing to remember is that the supervising therapist (whom you’re billing the services under) must be onsite. Because PTAs cannot bill for their own services, you must submit claims under an onsite supervising PT’s credentials. Regardless of your state practice act rules, the supervising therapist should cosign the billing note to ensure that you bill the PTA’s services correctly. While this can be a workflow challenge and potentially increase the therapist’s workload, it will ensure that your clinic is compliant with billing.

When billing for services under a PT license and NPI, sign in box 31 on the CMS 1500 claim form before submitting it for payment. By signing in box 31 (i.e., cosigning the note for your PTA or applying your name and credentials to bill under), you are certifying that:

  • The claim is accurate;
  • You have completed the documentation to support the claim; and
  • Either you provided the service or a PTA provided the service under your direct onsite supervision.

Once the PTA has documented services for a treatment Date of Service, he or she should forward the note to the onsite supervising PT. (Remember, it may not be the primary therapist if that PT is not onsite at the time of treatment). At the bottom of the Daily Note billing sheet, there is a forwarding drop down menu that lists all active PTs in your clinic, so that the PTA can appropriately forward the note.

In the upper right-hand corner of the PT’s dashboard within WebPT, there is an alert for “Incomplete Cosign Docs.” This is where PTs can find the PTA’s notes. Finalizing the note from the Plan tab will allow both the PT and PTA’s signatures to appear on the note and more importantly, it will transfer the appropriate PT’s name and NPI number to bill the claim correctly. 

WebPT recommends you take all of the above steps when billing for Medicare and commercial insurances.

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Heidi Jannenga PT

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