Author Topic: Need Help: FL Medicare part B outpatient therapy billing  (Read 1580 times)

KARREN

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Need Help: FL Medicare part B outpatient therapy billing
« on: November 30, 2014, 08:23:11 AM »
Need some help:
 I am concern if a D.O. can bill outpatient therapy treatment services to Medicare.
I understand option (A)
My concerns is option (B)

Scenario:
A group practice, we have a D.O. that is doing some therapy services on a few Medicare patients. 
My question is can the D.O. be the referring physician as well as the treating physician? 
His information prints in box 17 & 17a  as well as box 24J,  with the group information in box 33a.  Is this correct? 

A)   I understand when a physical therapist is rendering the services when billing Medicare you should bill the initial eval like this.   (with the referring doc info in box 17 & 17a and the physical therapist npi in box 24j and the group info in box 33a)
1st visit         10TH visit   
97001           97002 (re-eval)
97014 GP          97014 GP
97112 GP           97112 GP
97530 GP          97530 GP
G8981 CK GP       G8981 CK GP
G8982 CI GP      G8982 CI GP

   
B)   But, what about when the D.O. is rendering the services (he is the refer & rendering prov, he does the plan of care etc..) should the initial eval & therapy be billed like this and Is this correct?

       Example
1st visit         10th visit
99203 25          99213 or whichever E/M eval code the doctor provides
97014 GP          97014 GP
97110 GP           97110 GP
97032 GP           97032 GP   
97035 GP         97035 GP
G8981 CM GP       G8981 CK CP
G8982 CI GP      G8982 CI GP




Thanks!

Merry

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Re: Need Help: FL Medicare part B outpatient therapy billing
« Reply #1 on: November 30, 2014, 04:01:49 PM »
My thinking is that the answer is no. My understanding is that only a licensed PT can perform these services to be reimbursed by Medicare. Since an MD cannot be reimbursed, I believe that a D.O. would not be..but interested to hear from others.

shanbull

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Re: Need Help: FL Medicare part B outpatient therapy billing
« Reply #2 on: December 01, 2014, 10:33:31 AM »
My thinking is that the answer is no. My understanding is that only a licensed PT can perform these services to be reimbursed by Medicare. Since an MD cannot be reimbursed, I believe that a D.O. would not be..but interested to hear from others.

This is the rule yes, but it does leave room for differences in state definitions of who qualifies as a "therapist" and who can be licensed as such. I looked through the LCD's for Florida and did not find any differences from the national Medicare guidelines. This means the definition of who can provide physical therapy services defaults to the Medicare Benefit Policy Manual Chapter 15, Section 230.1 A-D:

Quote
230.1 - Practice of Physical Therapy
(Rev. 179, Issued: 01-14-14, Effective: 01-07-14, Implementation: 01-07-14)
A. General
Physical therapy services are those services provided within the scope of practice of
physical therapists and necessary for the diagnosis and treatment of impairments,
functional limitations, disabilities or changes in physical function and health status.
(See Pub. 100-03, the Medicare National Coverage Determinations Manual, for specific
conditions or services.) For descriptions of aquatic therapy in a community center pool
see section 220C of this chapter.
B. Qualified Physical Therapist Defined
Reference: 42CFR484.4
The new personnel qualifications for physical therapists were discussed in the 2008
Physician Fee Schedule. See the Federal Register of November 27, 2007, for the full
text. See also the correction notice for this rule, published in the Federal Register on
January 15, 2008.
The regulation provides that a qualified physical therapist (PT) is a person who is
licensed, if applicable, as a PT by the state in which he or she is practicing unless
licensure does not apply, has graduated from an accredited PT education program and
passed a national examination approved by the state in which PT services are provided.
The phrase, “by the state in which practicing” includes any authorization to practice
provided by the same state in which the service is provided, including temporary
licensure, regardless of the location of the entity billing the services. The curriculum
accreditation is provided by the Commission on Accreditation in Physical Therapy
Education (CAPTE) or, for those who graduated before CAPTE, curriculum approval
was provided by the American Physical Therapy Association (APTA). For
internationally educated PTs, curricula are approved by a credentials evaluation
organization either approved by the APTA or identified in 8 CFR 212.15(e) as it relates
to PTs. For example, in 2007, 8 CFR 212.15(e) approved the credentials evaluation
provided by the Federation of State Boards of Physical Therapy (FSBPT) and the Foreign
Credentialing Commission on Physical Therapy (FCCPT). The requirements above
apply to all PTs effective January 1, 2010, if they have not met any of the following
requirements prior to January 1, 2010.
Physical therapists whose current license was obtained on or prior to December 31, 2009,
qualify to provide PT services to Medicare beneficiaries if they:
• graduated from a CAPTE approved program in PT on or before December 31,
2009 (examination is not required); or,
• graduated on or before December 31, 2009, from a PT program outside the U.S.
that is determined to be substantially equivalent to a U.S. program by a
credentials evaluating organization approved by either the APTA or identified in
8 CFR 212.15(e) and also passed an examination for PTs approved by the state in
which practicing.
Or, PTs whose current license was obtained before January 1, 2008, may meet the
requirements in place on that date (i.e., graduation from a curriculum approved by
either the APTA, the Committee on Allied Health Education and Accreditation of
the American Medical Association, or both).Or, PTs meet the requirements who are
currently licensed and were licensed or qualified as a PT on or before December 31, 1977,
and had 2 years appropriate experience as a PT, and passed a proficiency examination conducted,
 approved, or sponsored by the U.S. Public Health Service.
Or, PTs meet the requirements if they are currently licensed and before January 1,
1966, they were:
• admitted to membership by the APTA; or
• admitted to registration by the American Registry of Physical Therapists;
or
• graduated from a 4-year PT curriculum approved by a State Department of
Education; or
• licensed or registered and prior to January 1, 1970, they had 15 years of
full-time experience in PT under the order and direction of attending and
referring doctors of medicine or osteopathy.
Or, PTs meet requirements if they are currently licensed and they were trained
outside the U.S. before January 1, 2008, and after 1928 graduated from a PT
curriculum approved in the country in which the curriculum was located, if that
country had an organization that was a member of the World Confederation for
Physical Therapy, and that PT qualified as a member of the organization.
For outpatient PT services that are provided incident to the services of physicians/NPPs,
the requirement for PT licensure does not apply; all other personnel qualifications do
apply. The qualified personnel providing PT services incident to the services of a
physician/NPP must be trained in an accredited PT curriculum. For example, a person
who, on or before December 31, 2009, graduated from a PT curriculum accredited by
CAPTE, but who has not passed the national examination or obtained a license, could
provide Medicare outpatient PT therapy services incident to the services of a
physician/NPP if the physician assumes responsibility for the services according to the
incident to policies. On or after January 1, 2010, although licensure does not apply, both
education and examination requirements that are effective January 1, 2010, apply to
qualified personnel who provide PT services incident to the services of a physician/NPP.
C. Services of Physical Therapy Support Personnel
Reference: 42CFR 484.4
Personnel Qualifications. The new personnel qualifications for physical therapist
assistants (PTA) were discussed in the 2008 Physician Fee Schedule. See the Federal Register
 of November 27, 2007, for the full text. See also the correction notice for this
rule, published in the Federal Register on January 15, 2008.
The regulation provides that a qualified PTA is a person who is licensed as a PTA unless
licensure does not apply, is registered or certified, if applicable, as a PTA by the state in
which practicing, and graduated from an approved curriculum for PTAs, and passed a
national examination for PTAs. The phrase, “by the state in which practicing” includes
any authorization to practice provided by the same state in which the service is provided,
including temporary licensure, regardless of the location or the entity billing for the
services. Approval for the curriculum is provided by CAPTE or, if internationally or
military trained PTAs apply, approval will be through a credentialing body for the
curriculum for PTAs identified by either the American Physical Therapy Association or
identified in 8 CFR 212.15(e). A national examination for PTAs is, for example the one
furnished by the Federation of State Boards of Physical Therapy. These requirements
above apply to all PTAs effective January 1, 2010, if they have not met any of the
following requirements prior to January 1, 2010.
Those PTAs also qualify who, on or before December 31, 2009, are licensed, registered
or certified as a PTA and met one of the two following requirements:
1. Is licensed or otherwise regulated in the state in which practicing; or
2. In states that have no licensure or other regulations, or where licensure does
not apply, PTAs have:
o graduated on or before December 31, 2009, from a 2-year college-level
program approved by the APTA or CAPTE; and
o effective January 1, 2010, those PTAs must have both graduated from a
CAPTE approved curriculum and passed a national examination for PTAs;
or
PTAs may also qualify if they are licensed, registered or certified as a PTA, if applicable
and meet requirements in effect before January 1, 2008, that is,
• they have graduated before January 1, 2008, from a 2 year college level
program approved by the APTA; or
• on or before December 31, 1977, they were licensed or qualified as a PTA and
passed a proficiency examination conducted, approved, or sponsored by the
U.S. Public Health Service.
Services. The services of PTAs used when providing covered therapy benefits are
included as part of the covered service. These services are billed by the supervising
physical therapist. PTAs may not provide evaluative or assessment services, make
clinical judgments or decisions; develop, manage, or furnish skilled maintenance program services; or take responsibility for the service.
They act at the direction and under the
supervision of the treating physical therapist and in accordance with state laws.
A physical therapist must supervise PTAs. The level and frequency of supervision differs
by setting (and by state or local law). General supervision is required for PTAs in all
settings except private practice (which requires direct supervision) unless state practice
requirements are more stringent, in which case state or local requirements must be
followed. See specific settings for details. For example, in clinics, rehabilitation
agencies, and public health agencies, 42CFR485.713 indicates that when a PTA provides
services, either on or off the organization’s premises, those services are supervised by a
qualified physical therapist who makes an onsite supervisory visit at least once every 30
days or more frequently if required by state or local laws or regulation.
The services of a PTA shall not be billed as services incident to a physician/NPP’s
service, because they do not meet the qualifications of a therapist.
The cost of supplies (e.g., theraband, hand putty, electrodes) used in furnishing covered
therapy care is included in the payment for the HCPCS codes billed by the physical
therapist, and are, therefore, not separately billable. Separate coverage and billing
provisions apply to items that meet the definition of brace in §130.
Services provided by aides, even if under the supervision of a therapist, are not therapy
services and are not covered by Medicare. Although an aide may help the therapist by
providing unskilled services, those services that are unskilled are not covered by
Medicare and shall be denied as not reasonable and necessary if they are billed as therapy
services.
D. Application of Medicare Guidelines to PT Services
This subsection will be used in the future to illustrate the application of the above
guidelines to some of the physical therapy modalities and procedures utilized in the
treatment of patients.
« Last Edit: December 01, 2014, 10:35:29 AM by shanbull »