On the WebPT Blog, one of the more common topics we receive questions on is cosignature rules. And to be honest, the answers aren’t always easy to find. For that reason, we’ve put together this quick guide on when therapists can—and should—cosign documentation. Read on to learn more!
1. Not When a Therapist is Awaiting Medicare Credentialing
Any therapist who works with insurance panels knows how long the credentialing process can take—and that’s a real pain in the neck (no pun intended) when you want to get to treating patients. Fortunately, as far as Medicare is concerned, a PT can begin seeing patients as soon as that therapist submits credentialing paperwork. However, while the therapist can begin the billing process for those dates of service, the clinic should hold off on sending the claims to Medicare until the therapist is officially credentialed. (Per timely filing rules, a practice can hold claims for up to one year from the treatment date.)
According to WebPT’s Erica McDermott, “Medicare won’t allow credentialed therapists to cosign claims for non-credentialed employees, so the uncredentialed therapist should reassign his or her individual Provider Transaction Access Number (PTAN) to the practice, and that practice should hold all the claims until he or she is fully credentialed.”
2. When a Therapist is Not Credentialed with a Non-Medicare Payer
Fortunately, many non-federal insurance carriers aren’t quite as stringent when it comes to non-credentialed providers performing and billing for therapy services. In the above-cited article, McDermott explains that “many non-Medicare insurance companies allow a credentialed therapist to cosign a non-credentialed therapist’s note if the cosigning therapist supervises the treatment.” The credentialed therapist must provide direct supervision in order to cosign the note—similar to supervision of PTA-led services. McDermott goes on to quote WebPT co-founder and Chief Clinical Officer Heidi Jannenga as saying, “cosigning should be used as a temporary fix only. It’s definitely not appropriate as a long-term solution.” That said, you should always verify this information with the payer directly and check your state practice act to ensure temporary cosignature is acceptable.
3. When a PTA Completes a Daily Note
According to compliance expert Rick Gawenda, PT, the president and CEO of Gawenda Seminars & Consulting, Medicare does not technically require a therapist cosignature on daily notes completed by physical therapist assistants (PTAs). That said, many payers and state practice acts do have this requirement, so for consistency (and to clearly indicate to Medicare that the therapist was supervising the PTA appropriately), we always encourage PTs to make this requirement part of their workflow for every daily note completed by an assistant. Furthermore, be sure to verify assistant-related cosignature requirements for your state and the patient’s insurance carrier.
Should PTs cosign PTA progress notes?
Aha, a trick question! While PTAs can contribute elements of a progress note, they cannot complete a progress note—nor should they sign progress notes.
As we explain in this blog on PTA and OTA supervision, PTAs may collect and provide documentation that supports the progress note, such as “the patient’s response to education and progress with certain skills” and “services provided as part of the intervention plan—including any home programs or adaptive equipment recommendations and the patient’s subjective comments about the services.” However, any assessment on a patient’s progress toward his or her therapy goals—including “any clinical observation or objective tests and measures”—must be observed and documented by the licensed physical therapist.
What about student-led services?
If you’re thinking this is another trick question, well, you’d be right! Under Medicare Part B, even with a PT’s cosignature, students cannot deliver services to patients (well, they can; the services simply won’t be reimbursed).
Now, that doesn’t mean a student can’t participate in the service at all. According to the APTA, a student may assist with services provided to Medicare beneficiaries if:
- “The qualified practitioner is recognized by the Medicare Part B beneficiary as the responsible professional within any session when services are delivered.
- “The qualified practitioner is present and in the room for the entire session. The student participates in the delivery of services when the qualified practitioner is directing the service, making the skilled judgment, and is responsible for the assessment and treatment.
- “The qualified practitioner is present in the room guiding the student in service delivery when the student is participating in the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time.
- “The qualified practitioner is responsible for the services and as such, signs all documentation.”
That said, there are cases in which a student actually can sign documentation (e.g., when a non-Medicare payer will reimburse for student-led services). In these instances, the supervising physical therapist will most likely need to cosign the documentation. As always, you should verify whether or not the insurance payer will reimburse student-led services prior to rendering them.
So, there you have it: the quick guide to when PTs can (or cannot) cosign documentation. Got any questions regarding cosignatures? Let us know in the comment section below!