Aug 30, 2012| Erica Cohen
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:
billing, emr, heidi jannenga, medicare, npi, physical therapy, pt compliance group, Tom Ambury, WebPT
- The supervising therapist performs the evaluation and establishes the plan of care.
- The services the PTA provides are medically necessary.
- 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).
- The supervising therapist must be immediately available to intervene. (i.e., he or she cannot be doing something that is uninterruptable.)
- The supervising therapist must have active ongoing involvement in the management and control of the patient's condition.
- If the patient presents with a new condition, the supervising therapist must see the patient.
- The PTA providing the service under the direct onsite supervision of the therapist must be an employee or an independent contractor of the practice.
Aug 29, 2012| Erica Cohen
Today’s blog post comes from copywriters Charlotte Bohnett and Erica Cohen.
Documentation sucks. We get it. We know it ain’t warm and fuzzy with rainbows and sunshine. It’s cumbersome and bang-your-head-against-a-wall frustrating. But as a physical therapist, it’s the name of the game.
According to the APTA, documentation is crucial because it:
- Serves as a record of patient care, including a report of the patient’s status, physical therapy management, and outcome of physical therapy intervention. It’s also a tool for the planning and provision of services and is a communication vehicle among providers.
- Tells others about our abilities, our unique body of knowledge, and the services we provide as PTs and PTAs.
- Demonstrates compliance with federal, state, payer, and local regulations.
- Provides a historical account of patient encounters clinics can use as evidence in potential legal situations.
- Demonstrates appropriate service use and reimbursement for many third-party payers.
- Is useful for policy or research purposes including outcomes analysis.
Aug 28, 2012| Charlotte Bohnett
Today's post comes from copywriters Erica Cohen and Charlotte Bohnett.
Last week WebPT hosted its most heavily attended webinar ever. Why so popular? Perhaps it was the brow-furrowing topic of compliance, or maybe it was our special guest—physical therapist and compliance expert Rick Gawenda of Gawenda Seminars. Together, Rick, moderator Mike Manheimer, and WebPT co-founder Heidi Jannenga, PT, set out to tackle compliance, making it entertaining, informative, and most importantly, understandable. Here’s a brief snapshot of what they discussed:
- What is compliance? How does it relate to Medicare and medical billing? And why should you care?
- What is the 2012 Therapy Cap?
- Modifiers and How to Use Them
- Manual Medical Review
- How does documenting with an EMR help you stay compliant?
- What is PQRS? How can you ensure compliance with outcome measures? What are the reporting methods?
Want the full kit and compliance kaboodle? Watch the webinar in its entirety below:CMS, compliance, emr, gawenda seminars, manual medical review, medical billing, medicare, modifiers, outcome measures, physical therapy, PQRS, PT best practices, rick gawenda, therapy cap, webinar
Aug 23, 2012| Charlotte Bohnett
This past weekend, I had the pleasure of doing a poster presentation at the Ancestral Health Symposium (AHS) held on the campus of Harvard Law School. It was one of the most exciting conferences I have ever attended, and I would like to share a bit about it.
The symposium is made possible through the work of the Ancestral Health Society. As explained on their website:
“The Ancestral Health Society fosters collaboration among scientists, healthcare professionals, and laypersons who study and communicate about health from an evolutionary perspective to develop solutions to our modern health challenges.
“The society’s primary role is to host the Ancestral Health Symposium, which is produced by a hobbyist volunteer model, utilizing the strengths of various individuals who proudly live an ancestral lifestyle.”ahs, ancestral health symposium, Ann Wendel, autoimmune illness, diabetes, direct access, health, nutrition, Paleo, physical therapy, PT best practices, wellness
Aug 21, 2012| Charlotte Bohnett
This month we’ve run the gamut on compliance topics. From autonomy to HIPAA myths, we’re on a mission to simplify this oh-so-weighty topic. While we’ve provided some tips and tricks for tackling compliance, sometimes you may find your clinic in a situation that requires absolute expertise. And because most small to mid-size clinics simply cannot afford to staff a full-time physical therapist and compliance officer, it’s a good idea to turn to a consultant. But there’s lots to consider before hiring any ol’ compliance consultant. Here are four to ponder:
As is the case with hiring for any position, experience is key. When shopping around for a compliance consultant, make sure they have the necessary credentials to ensure trustworthiness and peace of mind.
One must-have credential? Compliance certification! According to Nancy Beckley (@NancyBeckley), “CHC credential [is a] good place to start.” The Certified in Healthcare Compliance (CHC) website breaks down their certification process and details the following benefits of certification:
- Enhance the credibility of the compliance practitioner as well as the credibility of the compliance programs staffed by these certified professionals.
- Assure that each certified compliance practitioner has the broad knowledge base necessary to perform the compliance function.
- Establish professional standards and status for compliance professionals.
- Facilitate compliance work for compliance practitioners in dealing with other professionals in the industry, such as physicians and attorneys.
- Demonstrate the hard work and dedication necessary to perform the compliance task.
The Health Care Compliance Association also promotes CHC and encourages certification. In fact, the HCCA CEO wrote quite an impassioned letter regarding the topic entitled “Compliance certification by the profession, for the profession, and of the profession.” The AAPC also issues certification (Certified Professional Compliance Officer), which one can attain through an AAPC membership and rigorous examination.audit, best practices, billing, compliance, consultant, HIPAA, medical billing, medicare, physical therapy
Aug 20, 2012| Erica Cohen
Today's post comes from Tom Ambury, PT and compliance officer at PT Compliance Group. Thanks, Tom!
Greetings, WebPT Members! It is a pleasure to write for your blog, which aligns directly with our philosophy of helping our fellow therapists practice confidently, efficiently, and profitably. I also enjoyed meeting a number of you at Evolve 2012: Long Beach last month.
On July 30, "Health and Human Services (HHS) Secretary Kathleen Sebelius and Attorney General Eric Holder announced the launch of a ground-breaking partnership among the federal government, State officials, several leading private health insurance organizations, and other health care anti-fraud groups to prevent health care fraud." But this is really not news. The Federal Government has been sharing information, technology, and software for several years now. One example of this shared technology is the analytical software insurance companies use to identify statistical anomalies in claim submissions that might require further investigation.
Have you ever received a probe audit? You might have and didn’t even know it. A probe audit is like a recon mission; insurance companies collect intelligence to assess your documentation for weaknesses after they identified your clinic through a statistically aberrant pattern. Typically, the insurer only wants additional information to justify the medical necessity of a service you provided on one date. However, if you get several requests following one another by the same insurer, this is a probe audit.
Aug 16, 2012| Erica Cohen
Today's blog post comes from WebPT copywriters Charlotte Bohnett and Erica Cohen.
So, you probably remember a few weeks ago we wrote a pretty comprehensive overview on how you can ensure HIPAA compliance in your clinic. We covered everything from HIPAA basics to continuing education and training. In case you didn’t have a chance to read it, here’s a refresher:
US Congress established the Health Insurance Portability and Accountability Act in 1996. They implemented Title II: Preventing Health Care Fraud and Abuse to protect a patient’s private health information (PHI).
“Under this act, all healthcare providers, insurers, and their business associates may only collect, share, or use a patient’s PHI in approved methods and only for the explicit purpose of furthering patient care.
“A HIPAA violation can be anything from discussing identifiable patient information with your friends over lunch to leaving your not-password-protected work laptop open at a coffee shop. And, if you are found to have committed wrongful disclosure of individually identifiable health information, there are financial and criminal repercussions—including fines of up to $50,000 and one-year imprisonment.”
Now that we all know the basics, how about we tackle something a bit more tricky: HIPAA myths. There’s a lot of lore out there surrounding mobile devices and technology. What’s compliant? What isn’t? Can I use this? What about that? Let’s nip these worrisome quandaries in the bud here and now. Enter the WebPT mythbusters!
Aug 14, 2012| Erica Cohen
This blog post comes from WebPT copywriters Charlotte Bohnett and Erica Cohen.
PQRS is a royal pain in the you-know-what. We know. We don’t like it anymore than you do. But because CMS has now made it mandatory, we’re all for making the best of it. So how do you make peace with PQRS? Nail down the basics.
What is PQRS?
In an effort to improve quality of reporting in the healthcare industry, the Center for Medicare and Medicaid Services (CMS) created the Physician Quality Reporting System (PQRS), previously known as PQRI. PQRS mandates that physical therapists, occupational therapists, and qualified speech-language therapists meet the criteria for satisfactory reporting despite the word “physician” in the title. Beginning in 2013, non-compliance will result in penalties, which CMS will assess as fines (starting at 1.5% of your fee schedule) in 2015. However, if you are compliant, you will earn a 0.5% incentive payment on your total allowed charges during your reporting period.
Aug 13, 2012| Erica Cohen
The Middle Class Tax Relief and Job Creation Act of 2012 (HR3630) impacted physical therapists in private practice in terms of the Medicare therapy cap. First and foremost, HR3630 extended the therapy cap exception process through the 2012 calendar year. Secondly, it requires that the Centers for Medicare and Medicaid Services (CMS) apply the therapy cap limitations to hospital outpatient departments no later than October 1, 2012. The therapy cap for hospital outpatient departments concludes at the end of 2012 unless Congress passes additional legislation extending it into 2013.
So how does this affect the private practitioner? Currently, any outpatient therapy a Medicare beneficiary receives in a hospital outpatient therapy department between January 1 and September 30, 2012, does not count towards the $1,880 physical therapy and speech-language pathology cap. However, beginning on October 1, 2012, any therapy a Medicare beneficiary receives in a hospital outpatient department will now count toward the cap. Additionally, any outpatient therapy the Medicare beneficiary received in a hospital outpatient department from January 1 to September 30, 2012, will be applied retroactively to the $1,880 therapy cap limitations beginning on October 1, 2012.
Aug 9, 2012| Charlotte Bohnett
This blog post comes from WebPT copywriters Charlotte Bohnett and Erica Cohen.
Medicare compliance is one very tough nut to crack as is navigating the murky waters of medical insurance billing. We’ve filled this month’s blogs with all sorts of valuable and applicable information on everything from HIPAA to autonomy. But what Medicare obstacles do you grapple with daily? Today, let’s talk the five most frequently asked questions regarding Medicare.
1.) What is the Therapy Cap?
According to the APTA’s FAQs on the Therapy Cap and KX Modifier, under the Balanced Budget Act (BBA) of 1997, Congress placed an annual cap on rehabilitation services through Medicare. That means that Medicare will only reimburse you as the rehabilitation therapist up to a certain dollar amount per patient regardless of services provided.
In 2012, that annual per beneficiary therapy cap is $1,880 for physical therapy and speech language pathology services combined, and there is a separate $1,880 amount allotted for occupational therapy services.
Note: While the Medicare Advantage plan may apply a $1,880 therapy cap with an exceptions process, many Medicare Advantage plans have chosen not to apply a therapy cap in the past. Please check with your Medicare Advantage plan regarding its payment policies.
Read WebPT cofounder, COO, and PT Heidi Jannenga’s take on the therapy cap in her blog post, “Save the Day the CMS Way.”
APTA, billing, claims, CMS, compliance, feee schedule, insurance, kx modifier, medical, medicare, reimbursement, therapy cap