Several investigations in recent years have focused on allegedly excessive utilization of therapy services for SNF residents. SNFs have recently undergone a major reimbursement shift to a new system called PDPM (Patient Driven Payment Model), which rotates the focus of reimbursement away from the amount of therapy care provided to a focus on the degree of clinical complexity of the residents and their need for appropriate resources overall. Most of this excessive utilization is pushed by contract therapy companies to maintain and increase profits. Most contract therapy companies carry larger profit margins that the nursing homes themselves. One issue is the idea of “billable time” (a.k.a. the time you can actually bill a payer for).  In most cases, billable time is the time spent treating a patient. However, therapy companies walk (and usually cross) the line regarding what is “billable” and what is not. 

Here are the Top 5 clarifications of billable time:

5.  You cannot bill for unskilled prep time:
Medicare reimburses for skilled time only. Thus, any unskilled time dedicated to preparing a patient or treatment area for therapy cannot be counted as billable time, even if you, the licensed therapist, are completing those tasks.

4.  "Rounding up" is a no-no:
When it comes to recording treatment time, almost doesn’t count; in other words, if you provided a particular timed treatment for 14 minutes, that’s how many billable minutes you should record.

3.  You can bill for evaluations and re-evaluations by a therapist:
Most payers, including Medicare, allow therapists to bill for the initial evaluations necessary to establish plans of care (POCs). As for reevaluations, therapists can bill for the time they spend conducting these mid-POC assessments if there has been a significant change in the patient’s progress. Any help or contribution by an assistant during an evaluation is NOT billable time. Therapy assistants are not clinicians and should never bill any time towards an evaluation. It is also not appropriate to bill treatment time in this circumstance.  If an assistant assists in an evaluation, they are to be considered a “helper” and not doing a billable service.

2.  You can't bill multiple timed units due to the presence of multiple therapists:
If a single patient is receiving a single unit of treatment, you can only bill for that one unit—regardless of how many therapy professionals contributed to the delivery of that treatment.

1.  You CANNOT bill for documentation:
Documentation takes time, we all know that. Even if you have an EMR system that streamlines the process, there’s still a lot of effort that goes into creating notes that are complete, correct, and compliant. Unfortunately, you cannot bill for that effort, but your therapy company must pay you. You can bill for documentation completed during assessment and management in the presence of the patient.  But only for the time it takes to complete and document the assessment areas on the evaluation.  That does not mean just because the patient is in the room, you can bill for your time completing the POC and writing of the goals.  If your therapy company is forcing you to be more than 85% productive in a day, they are telling you to commit fraud and you should report this immediately.  The facility break room is required to display local and Federal hotline numbers.  You may also call 1-800-MEDICARE and report directly to CMS. You are protected by law from retaliation by the provider and therapy company if you need to report this.

Questions or concerns?  Feel free to send JMD Healthcare questions concerning therapy documentation or treatments to receive a FREE risk analysis with referenced Medicare Guidelines to help maintain compliance in your facility. 
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