Today's blog post comes from WebPT Co-Founder Heidi Jannenga, PT, MPT, ATC/L.
With the holidays quickly approaching, we thought this would be the perfect time to write a post on best practices when hiring a substitute, or contractor, to cover for you while you’re basking in the sun, boarding down a mountain, hanging out with the in-laws, or doing whatever it is you do to take a much deserved break.
When bringing in another therapist to treat your patients, many PTs face the “bill as” problem: in order to receive reimbursement from your insurance companies, the contractor you hire to cover you must be fully credentialed with the same insurance companies whose beneficiaries you treat. One of the best ways to assure this is to seek out a contractor from a qualified agency with vetted insurance credentials. This may be a slightly more costly way of doing things compared to simply hiring a friend or associate, but in order to “bill as” correctly, hiring a fully credentialed contractor is your best choice. While this is important for all insurance companies, it is imperative that if you treat Medicare patients, the contractor who steps in for you while you’re on vacation be Medicare credentialed. Otherwise, you risk problems beyond just denied reimbursements.
Some of you may have heard of Locum Tenens, which means “placeholder” in Latin; a person who temporarily fulfills the duties of another. Physicians have the luxury of simply adding a Q6 modifier to the treatment claim to indicate that a replacement physician provided the services on this particular day. Therapists, however, do not.
Along the same line of credentialing questions, what do you do when you’ve hired a brand new graduate or new employee waiting to be credentialed with your clinic? Specifically for Medicare, as long as his or her paperwork has been sent in and is pending CMS’s approval, the therapist can begin to treat patients. However, your practice must hold all billing claims for that new therapist (up to one year from the visit Date of Service, based on timely filing rules) until he or she receives credentialing approval. Medicare does not allow a cosigner on claims for contract or non-Medicare credentialed employees. The contract or uncredentialed therapist would need to reassign his or her individual Provider Transaction Access Number (PTAN) to your group, and then you would hold the claims until he or she is approved.
For most other insurances, a credentialed therapist may co-sign the note if the co-signing therapist supervised the treatment the contractor or uncredentialed therapist provided. Similar to the rules dictating how to bill for a PTA, the credentialed therapist must provide direct onsite supervision (i.e., he or she can be in the same building but not necessarily in the same room) and must be immediately available to intervene (i.e., he or she cannot be doing something that is uninterruptable) in order to co-sign on the note. This is only a temporary fix, though, and therapists should not use this fix for long-term coverage. We also highly recommend checking with your insurance companies to get specifics on coverage rules as each may have their own requirements. Again, you can obtain the best and most compliant coverage through an agency. This way you won’t need to worry about having to refund insurances for services rendered inappropriately.
If you’re a WebPT Member, you can enable note forwarding capabilities for co-signing within the system by contacting your Success Rep or emailing firstname.lastname@example.org. Please note that by co-signing a note within WebPT, you as the credentialed therapists are attesting you’re actively supervising the uncredentialed PT and are thus ultimately responsible for that patient’s care.
Follow these best practices and you’ll be able to rest easy on your vacation knowing that your patients—and your clinic—are in the best possible hands.