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Subject: News from Encompass Consulting & Education, L=
LC
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Medicare News and Rules for Therapists
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Encompass Con=
sulting
& Education, LLC <=
span
style=3D'font-family:"Palatino Linotype","serif"'>E-Newsletter
March 2010 &=
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nbsp; &nbs=
p; Vol
5, Issue 3
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Dear Pauline,
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![3D"Pauline](3D"http://origin.ih.constantcontact.com/fs035/1101399613904=)
What an up and down month for healthcare. The&nb=
sp;good
news is that we have the Therapy Exception Process in place till
the end of the year. The not so good news is that the Patient
Protection and Affordable Care Act (PPACA), the Healthcare Refo=
rm
Bill did not address the 21% plus decrease in reimbursement for=
the
Fee Schedule. However, there is a move to address that in the n=
ext
week or so. See "News
You Can Use" for further information.=
Thanks to all of you who took the time to comple=
te
last month's survey. We have taken note of your comments and wi=
ll do
our best to provide what you need. We will be sending
out invitations for our latest survey, Planning for Cruzin'
CEUs, in the next day or two, please take the t=
ime
to respond.
The RACs have expanded their list of issues,
however, they are focusing on Hospital DRGs and DME. For the mo=
ment
the rest of us are being given a break, but only from the RACs.
The other contractors are hard at work. Palmetto GBA,=
the
MAC for J1 has published the list of denials for January 2=
010.
We have edited the information for Part A providers. See
"=
Update
on Medical Review Activities".
"<=
/strong>Tip of the Month" is information on the "legible signat=
ure
issue. CMS has issued a transmittal addressing that topic. =
;
Encompass Seminars:=
We have finalized the locations and dates of our
2010 seminars. We have added a "Limited Edition"
presentation "RUG$ to Riche$" which will be presented=
in
May, June and July. It focuses on strategies to make the transi=
tion
to the MDS 3.0 less painful. You can find out more information
through the SNF seminar Quick Link. If you would like to sponsor one of the
locations or if you would like us to come to your area, let me
know.
In our Q&A
section we address areas of interest to both SNF and Outpatient
providers.
Please feel free to forward this Newsletter to
anyone you believe would be interested in its content. Please =
use
the link at the end of the newsletter to forward to a friend. T=
his
way we can keep track of forwards and improve our content.=
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News =
You
Can Use
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As
I mentioned, the PPACA that was signed into law by President
Obama did contain a 1 year continuation of the current Therapy Cap
Exception Process. It was made retroactive to January 1st and will
expire on December 31st 2010. More "Deja vu all aver
again". However, the bill did not address the planned reduct=
ion
in payment for the CPT codes for Medicare. The 3 month extension =
of
the 2009 rates expires on March 31st.
CMS
has taken action on this and has told the contractors to hold cla=
ims
of service from April 1st for 14 days. They will be working with
congress to address this concern and obviously believe that there
could be some action to reconcile this problem. Keep up to date w=
ith
this through our Website.
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Update on Medical Review Activities<=
/span>
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Palmetto,
GBA, the MAC for Jurisdiction 1 which includes California, publis=
hed
the January denials in claims for Part A Providers. We have edited
the information along with hits for avoiding the pitfalls. Althou=
gh
this is one jurisdiction, it can apply to all providers through M=
edicare.
The denial list includes Part B services provided by Hospitals and
SNF and Part A SNF claims.
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Surveys with YOU
in mind
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A
BIG Thank You
to those of you who completed our survey in February/March. Your
views and comments have been noted and I will work to integrate t=
hem
over time.
We
have already implemented some of the suggestions for days and top=
ics.
Our Limited Edition seminar will focus on the upcoming changes for
SNF occurring October 1st. We are also working on starting Webinar
for those of you in "faraway places".=
Our latest survey is about our "CRUZIN' CEUs" program. A
few years ago we did our Medicare Made Easy on the Carnival Liber=
ty
out of Miami. It was a 6 day cruise and on the 2 days at sea we h=
ad
the seminar. What was really nice about it was that by providing a
break between each session, the program was not quite as
overwhelming, and the participants got to spend time with friends=
and
family and see exotic places.
We are looking at doing the cruise again next year and want to fi=
nd
out if we have interest. We are starting to plan it now as the cr=
uise
lines want numbers way in advance and we want to get you the best
prices. The results will be in our next newsletter.
And
finally, there were 2 responders in our January newsletter that
indicated that they would be interested in providing content.
Unfortunately, I didn't get their e-mail address so would you
please contact me directly at pmfranko@encompassmedicare.com=
Instead of including the survey in the Newsletter,=
I
will be sending you a direct invitation following the distributio=
n of
the Newsletter. This is so that I can identify who has contributed
and reply if necessary to any of your comments. This month's surv=
ey
will assist me in designing our seminars and our future Webinar.
Thank you in advance for taking the time to complete it and
that should only take less than 5 minutes of your time.=
If you prefer to remain anonymous, you can go dire=
ctly
to the survey from the following link.
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Tip of the Month<=
/span>
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We
have been addressing the concern of the "Legable
Identifyer" as it relates to the Medical Review Process for =
some
time now. In the middle of March, CMS issued a transmittal to up =
date
the Program Integrity Manual. We have edited the transmittal so t=
hat it
relates to Rehab Services and excluded areas related to other typ=
es
of providers. Use the link to obtain the information.<=
/span>
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Q&A for SNF
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The following was a question brought up at our
Medicare Made Easy Seminar in Charlotte, NC last month. We had as=
ked
for Fact or Fiction questions and this one was very interesting to
say the least.
Question: A presenter =
;of
another course said that the 25% Group Rule only pertains to
when the resident is in an assessment. So she was saying that you=
can
do group all the time or a lot more if they are not in an
assessment.
Answer: The first statem=
ent
is sort of correct in the fact that, during the observation or
look-back period, a maximum of 25% of the total time can come
from group therapy. If more than that time has been provided, whi=
ch
is not prohibited, you can only count 25% of the total time =
to
create the RUG from those group activities for each discipline. So
for example, if the direct time was a total of 150 minutes a=
nd
the group time was 90 minutes, then only 50 minutes of that time =
can
be included on the MDS. However, if the total direct time was&nbs=
p; 210
minutes then 70 minutes of the group time could be included.
Now
for the next part. the observation period is chosen to portray the
most accurate needs of the patient which then sets up the appropr=
iate
payment for that care during the timeframe covered by that PPS
assessment. On Medical Review, the reviewer first looks at the
services provided during that observation period and then if the
level appears appropriate, they then review the balance of the ti=
me
that the payment covers. They will then look at the next observat=
ion
period followed by the rest of the covered time for that MDS, etc.
So, if the facility demonstrates a practice of increasing group
activity outside of an observation period and decreases it when t=
he
next observation period occurs, it certainly would be considered
inappropriate treatment as the observation period did not represe=
nt
the actual treatment that the therapist believed was appropriate.=
So,
the best I can say is that it would be considered an abusive prac=
tice
and you might get the RUG level reduced to what you were actually
providing. The worst I can say is the Medicare 5 letter F word, t=
hat
could get you into deep trouble.
CMS
and the contractors expect changes to occur as the patient respon=
ds
to treatment and so do not expect the identical number of minutes=
of
service through the whole of the covered period. BUT! If you show=
a
pattern of changing treatment when in an observation period and a
different practice when outside of the period, that could lead to
further investigation.
Beware
of October 1st. If you are asked to provide one-one-one when in an
observation period and increase to concurrent when outside of it,=
it
is fraud and abuse AND you could lose your license.
Remember,
it is your responsibility to know the RULES, that's why we have t=
his
company to make sure you are "Getting it right from the
start".
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Q&A for Outpatient Part B=
<=
/span>
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This
question was asked at our Part B seminar last month under the Fac=
t or
Fiction questions.
Questio=
n: Does
our documentation have to support our billing? For instance, 25
minutes of therex and 25 minutes of self-care. It is 50 total
minutes, but you would need to adjust your minutes because it is =
not
4 units but 3 units. So do you bill it as 22 minutes of therex an=
d 28
minutes of self-care which would truly be 3 units and not just
billing the code that offers the most reimbursement? This is real=
ly a
problem when your computer will not let you complete the bill bec=
ause
it does not meet the 8 minute rule for the appropriate units.&nbs=
p;It
would show 4 units but only 50 minutes, so we are forced to fix
it.
Answer:
YES!
Documentation must support services billed, however, they do not =
have
a regulation requiring that the actual minutes of service per CPT
code is recorded. They say that it is optional but the total dire=
ct
time is what supports the units billed. Therefore, because we are
subject to "systems" on the computer, what you put into=
the
system to generate your bill is not what the reviewer sees. I do =
not
look at this as a fraudulent activity as the number of units bill=
ed
should be supported by the documentation of what the therapist did
that was skilled.
So
entering time in the computer to generate the appropriate number =
of
units for each code is necessary for billing and administration. =
So,
your actual documentation in the medical record must show, for ea=
ch
treatment encounter note, the total treatment time which includes
both direct code times and supervised code times, but not non-ski=
lled
time, and the a second time indicating the total time spent on the
direct codes. So in your example, total treatment time would be 50
minutes, direct treatment time would be 50 minutes generating a
charge of 3 units with allocation of 2 units to 1 code and 1 unit=
to
the other code.
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Medicare News and Rules for therapists is brought =
to
you by Encompass Consulting & Education, LLC. A therapist own=
ed
company specializing in Consulting & Educational services for
therapists and other professionals providing Medicare services in
SNF, Rehab Agencies, Private Practice and Hospital Outpatient cli=
nics.
Pauline M. Franko, PT, MCSP is owner and CEO of the
company and is also known as the "Medicare Advisor"
columnist for the "Advance for" family of News Magazine
providing answers to Medicare questions for over 10 years. She al=
so
acts a resource for the respected Eli Reports and matters concern=
ing
rehab services and Medicare.
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Thank you so much for subscribing to our Newslette=
r.
Please feel free to forward this to anyone you believe would=
be
interested in receiving news about Medicare. Please use the link
below, as this way we are able to track how many of you are
forwarding it to your friens and associates.
Pauline Franko
Encompass Consulting & Education, LLC
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Encompass Consulting
& Education, LLC | 8114 NW 100th Terrace | Tamarac | FL | 33321-1=
259
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