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 in 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).
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. Furthermore, both 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.
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.”
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.
For more information regarding co-treatment—including three clinical examples—check out the joint guidelines referenced above. Still have questions? Leave ’em in the comment section below.