Therapy:
THERAPY UTILIZATION GUIDELINES TO HIT AGENCIES
Published on Mon Jan 15, 2007
Will your therapy visit number fit under a new coverage policy limit?
The spotlight on home health therapy continues to heat up with a new local coverage determination that will affect providers in 16 states--and maybe more.
No April Fool's joke: Regional home health intermediary Cahaba GBA proposed the LCD for home health therapy last August and has now issued the finalized determination for an effective date of April 1. Other RHHIs soon may follow suit to address the therapy hot topic, industry veterans predict.
Hot button: One of the hotly contested components of the new LCD are the utilization guidelines Cahaba sets down for each therapy service.
Commenters on the original draft policy urged the intermediary to leave out specific visit numbers.
But Cahaba defends the inclusion in the comments section of the new policy. "We are responding to home health providers' overwhelming requests for guidance in this area," the intermediary maintains.
Cahaba did "back down some" on the visit guidelines, notes physical therapist Cindy Krafft, consultant with UHSA.
The LCD now stresses that "utilization guidelines (i.e. number of visits) mentioned throughout the LCD serve as only a guideline and DO NOT imply coverage or non-coverage of a service therein." The policy adds that "services must be reasonable and necessary for each individual visit, as supported by the plan of treatment and the therapists' documentation, based on an assessment of each beneficiary's individual care needs."
But the visit guidelines "could still cause concern," Krafft cautions. Most of that language was in the draft LCD as well, notes the National Association for Home Care & Hospice. CPT Codes Cause Confusion In fact, the finalized LCD looks very much like the proposed one, NAHC says. "No substantive chan-ges were made from the draft document," the trade group tells its members.
A major point of confusion is that in the coverage policy, visit numbers and documentation recommendations are organized by CPT code--but home health agencies don't bill therapy using those codes.
Trap: HHAs may think they have to start using CPT codes under this policy, worries consultant Sharon Litwin with 5 Star Consultants in Ballwin, MO.
"Home health agencies are not required to document CPT codes in clinical records or on claims," one commenter protested. "The inclusion of CPT codes in this LCD will create confusion on the part of physical therapists and, potentially, medical reviewers, who might expect to find them in clinical documentation."
Justification: Cahaba defends its use of CPT codes. "A significant number of therapists often work across multiple bill types," the intermediary responds. "Organizing by code was geared towards the therapists' ease in transitioning among these bill types."
But in fact, a lot of therapists don't work in other settings, Krafft argues. "Many home health PTs have no idea about CPT codes [...]
