HOME HEALTH:
Be Sure Your Therapy Visit Number Fits Under A New Coverage Policy Limit
Published on Mon Mar 12, 2007
Stay alert: Therapy utilization guidelines to hit agencies.
The feds and payers have had their eyes on home health therapy the last few years as PPS has made its footprint in Medicare Part A coverage. That spotlight 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 local coverage determination (LCD) for home health therapy last August and has now issued the finalized determination to take effect April 1. Other Regional Home Health Intermediaries soon may follow suit to address the therapy hot topic, industry veterans predict.
Hot button: One of the contested components of the new LCD is 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 new policy's comments section. "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 Cindy Krafft, MS, PT, COS-C, consultant with Atlanta-based 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 and Hospice. CPT Codes Cause Confusion In fact, the finalized LCD looks very much like the proposed one, NAHC says. "No substantive changes 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 [under Medicare Part A] 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 [...]
