If you treat in a setting that offers multiple types of therapy (e.g. physical therapy, occupational therapy, and/or speech-language pathology), then you likely have—or will—come upon a situation in which it is in a patient’s best interest to receive treatment from more than one discipline during a single session. And while this practice is absolutely permissible under Medicare policy, there are some special rules governing the manner in which you provide—and bill for—such services. These rules vary based on whether you are billing under Part A (which includes services provided in skilled nursing facilities) or Part B (which includes services provided in clinics, private practices, hospital outpatient facilities, and, in some cases, skilled nursing facilities).
Medicare Part A Co-Treatment Rules
If, during a single treatment session, a patient receives therapy from two different practitioners working in two different disciplines (e.g., PT and OT), both therapists can bill for the entire treatment session separately. Each treating therapist, however, must ensure the length of time billed as co-treatment is equal in each other’s accounts. They must also ensure their documentation reflects the necessity for co-treatment (more on this in a bit) and delineates any services that were deemed as co-treatment. Furthermore, both therapists would be responsible for following all rules regarding mode, modalities, and student supervision—as well as all other federal, state, practice, and facility regulations—throughout the duration of the session.
Medicare Part B Co-Treatment Rules
If two therapists provide treatment—whether that treatment includes the same or different services—to a single patient at the same time, neither therapist can bill separately for the full session. Basically, the total time billed between the therapists must be equal to the exact duration of the treatment session. So either:
- One of the therapists may bill for the entire session, while the other bills nothing; or
- The two therapists can split the billed units between them.
Please note that when one of the treating therapists is a speech-language pathologist, the guidelines are a bit different. According to the ASHA Leader, “Because SLPs usually bill treatment codes that represent a session (rather than an amount of time), and because Medicare has no published minimum/maximum session length, the SLP would bill for one untimed session.” The OT or PT would then bill “the timed treatment codes for the occupational or physical therapy.”
There is one important point to keep in mind, courtesy of joint guidelines for co-treatment created by the American Speech-Language-Hearing Association (ASHA), the American Occupational Therapy Association (AOTA), and the American Physical Therapy Association (APTA): Therapists billing under either Part A or Part B should only provide co-treatment if the purpose for such treatment is to enhance the quality of care the patient receives. Practitioners should never co-treat simply because it is logistically more convenient to do so. If the therapists believe co-treatment is the best way to help the patient progress toward his or her goals, they must clearly document that rationale within their notes. Finally, therapists should not provide therapy in more than two disciplines during a single session.
To add some clarity to this murky rule, we’ve whipped up a couple of scenarios that would be well-suited for co-treatment below. Take note that in these cases, the patients being treated are Medicare part A beneficiaries, as co-treatment for Medicare Part B beneficiaries is much less common (see above).
A patient is receiving rehab therapy services to improve trunk control for seated tasks. The patient is receiving these services due to complications stemming from a stroke and therefore has difficulty with self-feeding while sitting in an armchair for meals. In this situation, both the PT and OT can justify co-treatment if the OT performed therapeutic activities (97350) and/or ADL/self-care training (97535) the worked on upper extremity and self-feeding tasks while the PT performed neuromuscular reeducation (97112), therapeutic exercises (97110), and/or therapeutic activities (97530) to improve trunk control while in a seated position.
A PT and an SLP are co-treating a 73-year-old patient who sustained a traumatic brain injury (TBI) falling from a ladder. The patient has difficulty with task segmentation and comprehension as well as an increased risk for falls. This patient has made progress in ambulation in controlled environments while working one-on-one with the PT, but their gait remains impaired and becomes severely ataxic in over-stimulated environments. The SLP chooses to treat task segmentation, multi-step direction following, and attention processing (G0515) while the PT treats gait deviations (97116) and motor control (97113) in varied task environments.
An OT and SLP are working in a rehabilitation unit and treating a patient with degenerative multiple sclerosis. The patient uses a power chair for community mobility and would like to maintain as much independence as possible, but as of late, has had increased difficulty with self-feeding. In addition, the patient’s neurologist has concerns with the patient aspirating their food when eating various meals. The two therapists decide to utilize co-treatment in one session whereby the SLP uses various strategies to instruct in safe swallowing techniques while the OT works to improve core control in the power chair as well as instruct in upper extremity coordination and self-feeding tasks. In this situation, the SLP could bill 92526 for swallowing function and/or oral function or feeding while the OT bills for neuromuscular reeducation (97112) and therapeutic activity (97530).
For more information regarding co-treatment—including more clinical examples—check out the joint guidelines (referenced above). And in case you are looking for more ways to automate and decrease the regulatory headache that is Medicare billing, check out WebPT’s billing software and services.
Still have questions? Leave ’em in the comment section below.