On August 15, 2007 Gordon Sato, the Regional Inspector General for Audit Services for the Office of the Inspector General sent a letter to Michael Bovarnick, Physical Therapist in Boca Raton, Florida.
The letter contained a report titled "Review of Florida Physical Therapist's Medicare Claims for Therapy Services provided during 2003".
In the report, the Office of the Inspector General found that Mr. Bovarnick had done the following:
- inappropriately used his provider identification number to bill for services performed or supervised by someone else
- the documentation for some therapy services did not meet Medicare requirements
- some therapy services were miscoded
- a plan of care did not meet Medicare requirements
The report went on to say this:
"The physical therapist did not have a thorough understanding of Medicare requirements and did not have effective policies and procedures in place to ensure that he billed Medicare only for services that met Medicare reimbursement requirements."
Finally, the Office of the Inspector General recommended that Mr. Bovarnick, the Physical Therapist, take the following course of action:
"Refund to the Medicare program $411,781 in unallowable payments for therapy services provided in 2003. Develop quality control procedures to ensure that therapy services are provided and documented in accordance with Medicare reimbursement requirements."
Physical therapy compliance experts cite Medical Necessity and Skilled Services documentation as two of the biggest areas of Medicare audit activity in physical therapy in the near future.
Medical Necessity is an area that physical therapists have not typically been taught (at least not when I graduated in 1992 from the University of Florida).
Medical Necessity is akin to Physical Therapy Diagnosis since impairments in range-of-motion (ROM) and strength constitute reversable finding that may be amenable to physical therapy interventions such as Therapeutic Exercise (CPT 97110) and Manual Therapy (CPT 97140).
Physical findings such as strength and ROM deficits that contribute to functional limitations and disabilities are what physical therapists treat.
Moreover, Mr. Bovarnick had this problem...
"The selected physical therapist operated five clinics that were leased and subleased in Florida during 2003. Nine physical therapists, including the selected physical therapist, and 10 physical therapy assistants worked in these clinics during this period."
Mr. Bovarnick not only had to police his own behavior and documentation but he had a staff of twenty physical therapy clinicians to train, motivate and supervise!
An impossible task? No, but a challenging one.
How should a manager approach the task of training, motivating and supervising a staff of physcal therapy clinicians to properly write notes and charts that will reliably withstand a Medicare audit?
- The physical therapy manager could invent or develop a proprietary Medicare compliance plan.
- The physical therapy manager could outsource Medicare compliance to consultants.
- The physical therapy manager could 'fly below the radar' (and leave money on the table - see this blog post Fly Below the Radar for further explanation).
- The physical therapy manager could make notes and charts easier, quicker and better for patient care by using Physical Therapy Diagnosis as the basis for all clinical decisions and the beginnings of all clinical documentation.
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