In many cases, physical therapy and occupational therapy go together like peanut butter and jelly. We often share similar goals and interventions, treat the same types of patients, and often share a need to clarify the billing rules that apply to our specialties.
This confusion leads to several questions, including this head-scratcher: how does a clinic bill for occupational therapy and then bill for physical therapy provided to a single patient on the same day?
While the specifics of how to bill for PT and OT treatment on the same service date can be murky, it’s possible to do—as long as you color within the lines.
Understand your payers’ rules.
Some payers will reimburse for different service types on the same day, while others will not. So, before you do anything else, confirm your payers’ stance.
Also, there might be specific guidelines attached to your payers’ policies. So, some insurance companies might reimburse for same-day PT and OT in particular settings (think inpatient rehab or acute hospital settings) but not in others (i.e., outpatient private practice).
How to bill PT and OT should be a secondary concern to ensuring your therapeutic services and documentation reflect that you’re providing the treatment best suited for your patients—no more and no less.
As discussed below, Medicare allows for billing occupational therapy and physical therapy services on the same day, but some rules govern this practice. And they differ depending on whether your patient is covered under Part A or Part B services.
Beware of billing for co-treatment.
Co-treatment can benefit patients and therapists alike, and it might be appropriate if a patient is more likely to reach their goals when multiple therapists work together to provide individual treatments during a single session. Therapists often opt to co-treat for safety reasons—like with high-complexity patients—but be aware that simply having a second person on hand to act as a contact guard (i.e., to prevent falls) is insufficient to justify billing for a second therapist’s services.
Perhaps even more frustrating is that the rules for co-treatment vary from setting to setting and payer to payer, so you must know the patient’s payer source. As Medicare tends to be the bellwether of such things, we have outlined some specifics below.
Inpatient Rehabilitation Facilities (IRFs)
Regarding IRFs, the Medicare Administrative Contractor (MAC), Noridian, states, “Co-treatment is when two clinicians from different disciplines provide different treatments to one resident at the same time.” As such, therapists who bill under Medicare Part A for services provided in an IRF setting may bill the full-time treated so long as their services are separate and distinctive to their discipline and treatment plan.
For example, if an OT and a PT co-treat from 10:30 AM to 11:30 AM, and the OT works on toileting strategies while the PT simultaneously addresses safe transfers, both clinicians could bill for that entire hour, provided they show proof of providing different treatments with separate end goals.
Please note that, per the Centers for Medicare and Medicaid (CMS), “The specific benefit to the patient of the co-treatment must be well-documented in the IRF medical record,” so do not forget to include the medical necessity of your co-treatment.
Surprisingly, the inpatient hospital setting does not have a set co-treatment policy—likely because inpatient hospitals are paid based on diagnosis-related groups (DRGs), not fee-for-service.
Noridian explains, “Both clinicians cannot each bill separately for the same or different service provided at the same time to the same patient.” Simply put, if the PT and OT treat together for 30 minutes, they must either split the time spent with the patient (e.g., 15 minutes each) or one discipline takes all the time.
Please note that Noridian is one of many MACs in the country, so although this advice falls into a safe zone for treatment, you may want to consult your region’s MAC for more specific details.
Outpatient Facilities and Private Practices (Part B)
Now let’s tackle billing under Medicare Part B (i.e., outpatient), which stipulates that providers cannot bill separately for different (or similar) therapy services provided to the same patient simultaneously.
So, even if a PT and OT co-treat a patient with a high complexity and low functional level in an outpatient setting for safety reasons, they cannot both bill for the entirety of their time. Instead, they must divide their minutes based on each therapist's services.
For example, if an OT and PT co-treat from 10:30 to 11:30 AM, the OT can bill for their portion of the hour (e.g., 10:30-11:00 AM) under OT codes, while the PT can bill for their share (e.g., 11:00-11:30 AM) under PT codes.
This same rule holds for outpatient hospitals, private practice, and SNF (Medicare Part B) settings.
Home Health (Part A)
When treating in-home care patients, there will almost certainly be instances when the physical therapist and occupational therapist must visit on the same day, albeit usually at different and distinct times. If your plan of care (POC) indicates that two separate clinicians must be in a patient’s home—and your documentation supports the medical necessity of both interventions—then both therapists can bill for their particular time.
The rules become somewhat murky if a patient’s case warrants PT and OT treatment simultaneously—as seen in other co-treatment settings. However, the American Speech-Language-Hearing Association (ASHA) has published joint guidelines with examples of when co-treatment is warranted, falling on the side that splitting the treatment time between providers appears to be the safest option to avoid claim denials or a targeted medical review.
Skilled Nursing Facilities (SNFs: Part A or Part B)
When treating patients in an SNF, figuring out how to bill for PT and OT services depends on whether the patient is a Medicare Part A or B beneficiary.
For SNF treatment billed under Part A, an OT and PT can provide different treatments to the same patient simultaneously—and each clinician can bill for their entire treatment session. But again, these co-treatments should be provided on a case-by-case basis according to the patient's needs—and the documentation must adequately support the reasons for the co-treatment.
Now, for SNF treatment billed under Part B, the rules are similar to those for outpatient settings: the PT and OT cannot charge for an entire session. Instead, they must split the units.
Mind your XP and 59 modifiers when billing for PT and OT.
If your outpatient facility offers OT and PT, and a patient wishes to book separate appointments on the same day, you may need to use a modifier.
Modifier XP applies to linked services delivered by different practitioners (for more on linked services, refer to this resource). The XP modifier is appropriate if an OT takes over treatment in the middle of a PT session.
In other cases—or if the payer does not yet require or recognize X modifiers—modifier 59 may be the appropriate mechanism to identify otherwise linked services that are, given the circumstances, reimbursed separately. For more information on modifier 59, check out this recent blog post that covers claim denials.
Billing processes have always been tricky, especially when determining how to bill for PT and OT. Do you have examples to share? Tell us your own billing stories.