The drive from Denver International Airport to Gaylord Rockies Resort and Convention Center, the site of the 2022 APTA Private Practice Section (PPS) Annual Conference and Exhibition, made me think of the classic ‘90s comedy Dumb and Dumber—specifically, the part when Harry laments to Lloyd, “I thought the Rocky Mountains would be rockier.” For those stepping off the plane expecting nothing but picturesque views, the area in question is more barren plains than mountainscape—which is an apt metaphor for rehab therapy, where the unexpected is always to be expected.
The unexpected isn’t always bad, however, and in this case was quite the pleasant surprise, as the fantastic resort was packed with enthusiastic attendees, intriguing exhibitors (WebPT included), and too many illuminating sessions for one person to attend. Nevertheless, here are the highlights of just some of what PPS 2022’s speakers had to offer.
How to Navigate a Medicare Auditor’s Focus
Medicare audits have been at the top of our minds lately, and like our own John Wallace, WebPT SVP of RCM, Mary R. Daulong, Business and Clinical Management Services President and CEO, is a wealth of information on the topic. As Daulong highlighted in her presentation, there are a few billing and documentation mistakes that can put you firmly in the sights of auditors:
- the lack of a signed plan of care;
- redundant coding that doesn’t demonstrate progress; and
- overbilling (or underbilling) are a few of the big, flashing lights that draw the attention of MACs.
But even careful billers can end up facing an audit, especially with the Comprehensive Error Rate Testing (CERT) audits being random.
What’s important is to understand how to be prepared for an audit in order to make it as smooth as possible for both parties; MACs are human, as Daulong noted, and the more frustrated they get with a disorganized and incomplete response, the more you’ll ultimately be penalized.
Daulong has a few key points to help you optimize the process:
- Have a good mail sorter. Don’t underestimate the importance of recognizing an Additional Documentation Request (ADR) as you receive it so that it doesn’t end up under a pile of mail. Daulong recommended having your sorter prioritize all mail from payers, and hanging on to the envelopes in case there’s a difference between the date on the request and the postmark in case there’s a question about when a response is due.
- Do it right the first time. Daulong emphasized the importance of reading, re-reading, and then reading again all instructions and requests—and then following them to the letter. You should also look to submit all required forms and documentation on time, if not early, and provide the exact forms required. Make sure that your documents are ordered and legible, and keep a copy of everything for yourself. It might not alter any errors, but making things simple for an auditor can go a long way towards helping your cause.
- Submit via hard copy or payer portal. Don’t fax any documents for your audits if at all possible; instead, rely upon the mail and online portals to submit paperwork. As Daulong pointed out, a fax can result in smudges and decreased legibility, which is the last thing you need.
- Don’t be afraid to appeal or rebut. Daulong’s take is that if you’re not appealing, you’re admitting to Medicare that they’ve caught you. If you feel justified in your documentation, don’t hesitate to appeal, even though it can be a difficult process. In the case of Supplemental Medical Review Contractor (SMRC) audits, Daulong emphasizes that rebutting requests from auditors can be necessary, as many can and will ask for documentation that isn’t required by statute, like short-term goals.
A Structured Mentorship Program to Recruit Staff, Develop Skills and Improve Your Bottom Line
Speaking of preparation, a growing number of DPT students are leaving school feeling that they’re not ready to start seeing patients, and residencies have been held forth as, if not the answer, at least one solution to that challenge. But is residency the right answer to that problem?
In her presentation, Neisha Wetzel, PT, DPT, GCS, OCS, Cert. MDT, Advanced Physical Therapy Solutions Owner, made the case for structured mentorships as a must-have for modern clinics— not only to better prepare new PTs (and some experienced ones too) but to help recruit those recent graduates to your clinic in the first place.
Clinics need to meet the personal and professional needs of PTs.
It’s not just that DPT grads are tentative about their relatively untested skills—millennial and Gen-Z providers are keen to be mentored so that they can maximize their growth opportunities and achieve their professional objectives in a way that (hopefully) maintains work-life balance. As much as anything, they want to feel seen and heard—and the clinic that can provide that connection has a recruiting advantage on those that don’t offer mentorship programs.
Find—or create—the mentorship program that works for you.
What makes mentorship programs both wonderful and challenging, according to Wetzel, is that there’s not a one-size-fits-all answer for every clinic. The process offered in her own clinic—regular meetings between mentor and mentee for set periods, a slow ramping-up of caseloads, regular check-ins on measurable goals—might not work as well for other clinic settings. And there’s also the financial aspect: setting aside time during the week or month to work with new hires is time that isn’t billable, and while your mentorship program might not come with the price tag of a residency, there’s the cost of potential lost productivity.
However, those challenges shouldn’t hold you back from creating your own mentorship program. Finding the right program might take a bit of trial-and-error to go with the lost revenue, but they’re worth a short-term loss for the long-term benefit. And as Wetzel notes from her own clinic, mentored employees outperformed those without mentoring enough to more than make up for the “cost.” Whatever route you decide to go, the most important thing is that the program is well-defined, staffed by capable and committed mentors, and is a priority regardless of schedule demands.
Medicare 201: Beyond the Basics
If you’ve ever worried that Medicare wasn’t complex enough, Rick Gawenda, PT, Founder and President of Gawenda Seminars and Consulting, was at the ready to disabuse you of such notions. He gave a wide-ranging talk, taking listeners even deeper into the weeds on everyone’s favorite topic—compliance—particularly on a few details that the average provider might not be aware of (but should be).
RVUs vs. GCPIs
For those wondering why they’re not getting the same reimbursements as providers in other regions, the difference in pay per CPT code across the country comes down to Geographic Price Cost Index (GCPI) rather than Relative Value Units (RVUs). While Work RVS, Practice Expense RVU and Malpractice RVU remain consistent nationwide, GCPI varies across the 112 payment localities and accounts for regional and practice-specific cost factors.
Multiple Procedure Payment Reduction (MPPR)
If you’ve noticed a reduction when billing multiple CPT codes, MPPR is to blame. As Gawenda explains, the highest practice expense value CPT code is exempted from MPPR, and this reimbursed at 100%; after that, any other “always therapy” codes have their practice expense value reduced by 50%. And MPPR isn’t for duplicate codes; if you’re billing four separate CPT codes, the three least valuable will still get a 50% reduction. Worse yet, there’s nothing that providers can do to get around it.
While Gawenda didn’t cover anything about CO or CQ modifiers that we haven’t already (not to brag), he did offer an interesting tidbit regarding private payers. Humana, Cigna, Tricare, and UnitedHealthcare have already implemented CO/CQ modifiers, and in Gawenda’s opinion, more will follow suit in 2023.
Qualified Medicare Beneficiary Program (QMB)
Not often discussed, QMB is a program that providers dealing with Medicare patients should be aware of all the same. Patients enrolled in QMB have Medicare as their primary insurance and Medicaid as their secondary, and per federal law, cannot be billed by providers for deductibles, coinsurance, or copayments for Medicare Part A or Part B services—which means providers can bill state Medicare programs for those costs. What’s more, nonparticipating providers are obligated to accept assignment for QMB patients
Advanced Beneficiary Notice of Noncoverage (ABNs)
Every provider should be familiar with ABNs, but are you using them correctly? Gawenda has a few tips on when and how to provide an ABN:
- To provide an ABN to a Medicare patient, you must be enrolled as a Medicare provider, either as participating or nonparticipating.
- ABNs are only for Medicare patients, not Medicare Advantage.
- Don’t offer generic or incomplete ABNs, or give blanket ABNs to every patient without a reason you believe a service will be denied.
- A patient’s social security number or Medicare number cannot be on the ABN in the “identification number” box.
- When offering an estimated cost, try to provide the actual cost or, if you’re forced to estimate, make sure that the costs won’t exceed that estimate.
- Don’t provide an ABN for services if you’re planning to use the KX modifier, or simply because a patient has reached the therapy threshold.
Part B Deductibles
If a patient hasn’t met the Part B deductible ($226 in 2023), the amount spent toward that deductible would count towards the therapy threshold. For patients who have already met the deductible, the full therapy threshold amount would be available. The dollar amount is taken from the respective CPT codes after the MPPR reduction but before the sequestration reduction.
Solving the “Supply Chain Shortage”: How to Hire and Retain the Best Personnel
Retention has been a big issue in rehab therapy, and Brian Gallagher, PT, MEG Business Management Founder and President, and Nicole Walczak, PT, MEG Business Management COO, offered their perspective on the problem—which can actually be chalked up to a few problems.
Solving the PT recruiting and staffing issues requires:
- A leadership mindset,
- Effective recruitment strategies, and
- A positive practice environment and company culture that attracts talent.
Be a manager as well as an entrepreneur.
The right leadership mindset, according to Gallagher and Walczak, is one that embraces “the infinite game”: always learning, always ready for surprises, and embracing and cultivating creativity. Leaders also need to balance their entrepreneurial instincts to keep innovating and moving to the next thing against the manager’s imperative to refine your processes—because if you’re always pressing toward new ideas, you won’t master your old ones.
Know your target demographic for recruiting.
The best recruitment strategies are ones tailored to your audience, whether you’re looking for Gen-X (or older), millennial, or Gen-Z providers. And there are differences, to be sure; while Gen-X is more interested in traditional work values like higher salary and advancement, younger generations are more conscious of work-life balance, or crafting a blend of work and personal life. So write your job descriptions and ads accordingly!
Start recruiting early—and make your clinic appealing to young PTs.
If you’re looking to get a head start on recruiting, implementing pre-PT programs or clinical education programs that partner with local universities to bring PT students into your clinic is a great way to not only train the next generation of PTs, but to also highlight your company culture to students you might want to hire in the future. But awareness is only one step—to reel in these new grads, you need to be able to offer attractive benefits like mentorship, educational incentives, student loan repayment, or a pay-for-performance model that emphasizes efficiency and quality over volume.
Company culture is vital to retention.
Once you land new recruits, you need to hold onto them—along with the seasoned therapists you already have on staff. Retention is just as important as recruitment to the success of a clinic, and is just as much of a struggle for clinic owners. As we found in our State of Rehab Therapy report, burnout and turnover are major issues plaguing rehab therapy, and unless action is taken, staffing issues will only get worse. That’s why Gallagher and Walscak highlighted the importance of a strong company culture in employee retention. If you’re engaging with employees, offering validation and acknowledgement, and introducing gamification to keep things fun, you’re miles ahead of other clinics.
Overall, the event was a fantastic mix of education, connection, and a little bit of fun. (I think the WebPT happy hour still has attendees lining up.) And with any luck, next year’s event in Austin will prove to be just as exciting, as perhaps a little weird.