HOSPITAL THERAPISTS:
Your Expectations Aren't Far From Part B Settings', CMS Says
Published on Mon Feb 12, 2007
Hospital rehabs: turn your eye to outpatient therapy policies.
If you are happily settled in your world of Medicare Part A policies, you may want to cross the fence to see what your colleagues in Part B settings are doing.
Why: The Centers for Medicare & Medicaid Services (CMS) announced in Transmittal 65 on Jan. 26 that hospital inpatient rehab settings, hospital acute care settings, critical access hospitals, long-term care hospitals and psychiatric hospitals under Part A are subject to the same documentation and provider requirements as Part B settings.
Find Out Where You're Off The Hook First and foremost, these new inpatient rules are not asking you to conform your billing practices to that of Part B settings. That means you will not have to face the therapy caps your outpatient colleagues are wrestling. You'll continue to bill using diagnostic related groups (DRGs) if you're in an acute care hospital setting, or by the inpatient rehabilitation facility (IRF) prospective payment system (PPS) if you're in an IRF setting.
SNFs and HHAs: You can count yourself out if you're a skilled nursing facility (SNF) or home health agency (HHA). "This transmittal specifically addresses hospital inpatient therapy services--it makes no mention of other Medicare Part A settings that have rehab services, such as SNFs and HHAs," says Angie Phillips, PT, president and CEO of Images & Associates, an Amarillo, TX- based physical therapy consulting firm. That means you're affected only if you're an acute hospital, critical access hospital, IRF, long-term care hospital or psychiatric hospital, she clarifies.
Exceptions: Although CMS directs you to Part B policies, it notes certain exceptions that won't apply to hospital Part A. For example, inpatient hospital therapy services will follow their own certification and re-certification requirements appropriate to the applicable PPS. Review The Meaning Of 'Therapy Services' One of the biggest challenges in conforming to Part B policies will be re-thinking what CMS does and doesn't consider skilled therapy. For example, a hospital staff member assisting a patient with independent activities between treatment sessions may be valuable to the patient's progress but is not a therapy service, according to the transmittal. In other words, unless the service requires a therapist's skills, CMS does not consider it a therapy service.
Don't miss: And you can't talk about skilled therapy services without considering qualified personnel and supervision policies as well. "Services provided by a technician or aide, regardless of the level of supervision, are not considered therapy services," Phillips says.
Important: In addition, IRFs must provide three hours of therapy per day, a minimum of five days a week--which is a tight squeeze for many post-acute patients. "Those organizations that have utilized non-licensed extenders under direct line of site supervision will need to [...]
