This post comes from PT Compliance Group compliance officer Tom Ambury, PT, and WebPT President Heidi Jannenga, PT, DPT, ATC/L.
We get a lot of questions when it comes to billing for private practice PT services. One of the most common has to do with billing for licensed PTAs—especially when Medicare and state practice acts have different requirements when it comes to supervision. Our advice? Adhere to the most stringent requirement, which usually comes from Medicare. Read on to learn how you can safely incorporate PTA services into your practice—and get reimbursed for them.
State laws and payer billing rules are two different things.
According to the APTA, Medicare allows therapist assistants to provide therapy services in an outpatient private practice setting—as long as those services are performed under the direct supervision of a licensed therapist. 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 such as a private practice, the following conditions must be met:
- 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 is in the same building, but not necessarily in the same room).
- The supervising therapist is immediately available to intervene. (i.e., he or she is not doing something uninterruptable).
- The supervising therapist has active ongoing involvement in the management and control of the patient’s condition.
- If the patient presents with a new condition, the supervising therapist sees the patient.
- The PTA providing the service under the direct onsite supervision of the therapist is an employee or independent contractor of the practice.
Medicare rules usually, well, rule.
The above-stated information applies to Medicare, specifically. While some private insurance carriers have their own rules, many defer to Medicare’s. In fact, there are numerous examples of providers getting more than a wrist slap for failing to adhere to Medicare’s rules in favor of the less stringent requirements laid out by their state practice acts. So, if your state law allows licensed PTAs to treat without direct onsite supervision, proceed at your own risk, because Medicare—and most commercial payers—do not. And you won’t be able to get paid for your services if you’re not following the payer’s billing rules to the letter.
Your documentation must support your claim.
Speaking of conditions for getting paid, your documentation must be complete, defensible, and supportive of your request for payment—whether you’re billing a patient, a commercial payer, or Medicare. If you’re billing for PTA-provided services, then be sure your documentation includes the following:
- Language stating that you—the licensed PT—reviewed your plan of care with the PTA who’s providing services under your direction and direct supervision.
- Notes from regular meetings where you review the patient’s progress with the PTA.
- A clear indication of when treatment advances to the next more complex or sophisticated task.
- Your signature as a cosigner on the daily note.
- A statement from the PTA that he or she “provided services under the direct supervision of (name of the supervising therapist).”
Your billing must be complete.
To properly bill for PTA-provided services, the supervising PT must be on site—because PTAs cannot bill for their own services. Instead, the supervising PT must bill using his or her own credentials. And no matter what your state practice act says, the supervising therapist should always co-sign the billing note to ensure that the PTA’s services are being billed correctly. While this may add an extra step into your already jam-packed workflow, it’s worth it because it will help keep your clinic’s billing compliant—and that can have a major impact on your bottom line.
WebPT makes billing for PTAs easy.
When billing for PTA-provided services under your license and NPI number, sign your name in box 31 on the CMS 1500 claim form before submitting the claim for payment. By doing so, you’re certifying that:
- the claim is accurate;
- you have completed the documentation to support the claim; and
- either you provided the services or a PTA provided the services under your direct onsite supervision.
Once the PTA has documented the services for a treatment date of service, then he or she should forward the note to the onsite supervising PT (not necessarily the primary PT, unless the primary PT is the one who is onsite supervising the PTA’s services). At the bottom of the daily note billing sheet within WebPT, there is a forwarding dropdown that lists all active PTs in your clinic. This is where the PTA can select the appropriate PT to forward the note.
In the upper-right corner of the therapist’s WebPT dashboard, there is an alert for “Incomplete Cosign Docs.” This is where you’ll find PTA notes. Finalizing the note from the Plan tab will ensure that both the PT’s and PTA’s signatures appear on the note and—more importantly—that the supervising PT’s name and NPI number will correctly populate on the claim. As a note, we recommend that you follow the same steps whether you’re billing Medicare or a commercial carrier. After all, this is one of those instances where you’re definitely better safe than sorry.
Looking for more information on billing for PTAs? Check out this resource and this one. Then, if you still have questions, drop us a comment, and we’ll do our best to track down an answer.