Can powerful new tools used by physical therapists prevent a Medicare audit?
If you write in your note tests that predict the outcome of treatment could that note be exempt from a "partial denial of a therapy claim" that requires oodles of handwritten narrative "trumpeting clinicians' concerns"?
Rather than trumpeting your concern in writing wouldn't you prefer to spend time thinking about how to get your patient better?
What new ways could you think of to provide 'value' to America's struggling healthcare marketplace?
| Sources of Value in Physical Therapy | |
|---|---|
| Old | New |
| Osteokinematics | Manipulation predictor variables |
| Gait analysis | Gait Velocity measurements |
| Narrative descriptors of "assistance" | Self-report scales (eg: ABC test) |
| Falls history for predicting future falls risk | Testing specified populations with known pre-test probabilities of falling down using tests with known likelihood ratios |
| Pathology model | Biopsychosocial model |
| Physicians' diagnosis | Physical Therapy Diagnosis |
Much as physicians inflate health care costs with defensive medicine so to are physical therapists forced to waste precious time, money and energy with defensive documentation. Most would agree that documentation doesn't add 'value' to healthcare.
Even if you get your patient better in a reasonable time frame using evidence based physical therapy Medicare can come in and retroactively snatch away your payment dollars if you haven't trumpeted your concern in your notes and charts that each and every intervention is 'skilled' - nevermind that no uniform definition of 'skilled therapy' exists.
Defensive Documentation and Defensive Medicine
The American Medical Association as gone on record saying it will support legislation aiming to shave costs on defensive medicine by providing immunity from lawsuits for physicians who practice evidence based medicine. Health and Human Services Department economists estimate America could save $60-108 billion per year with malpractice reform.
The Health Care OverUse Reform Today Act (HealthCOURT Act - H.R. 3372) contains language that provides immunity from lawsuits to physicians who practice evidence-based medicine. It's purpose is to
"...establish an affirmative defense in medical malpractice actions based on compliance with best practices guidelines"The HealthCOURT Act may not make it out of committee but Democrats seem willing to trade some aspect of malpractice reform for passage of a larger health care reform package.
The Medical Group Management Association (MGMA) sent this letter to Congress in May 2009 outlining their position on the use of evidence based guidelines and malpractice reform:
"Allow use of evidence-based guidelines to provide mitigating protection in professional liability cases.How does Defensive Medicine relate to "Skilled Therapy"?
In some circumstances allow these guideless to offer immunity."
Why did Medicare chose to use a 'skilled therapy' criteria to evaluate your notes and charts? Because they had no alternative source of value!
Today, in 2009, physical therapists create value by assigning patients to classification treatment groups based on the presence or absence of statistically determined predictor variables. Physical therapy evidence is much better today than it was 15-20 years ago when Medicare auditors first began scrutinizing PT charts and notes, en masse.
One of my blog readers asked me not long ago...
"If a physical therapist is performing the therapy then isn't it, by definition, skilled therapy?"I wasn't sure whether I should cry or laugh at the innocence, the naiveté displayed by this statement.
Over 40% of PT charges are reported to lack documentation supporting 'skilled therapy' - the result is 'maintenance therapy' unbillable to Medicare or most third party payers.
Skilled therapy has been in the Medicare Manuals since at least 1988, according to my research. The enforcement of skilled therapy, however, by the self-appointed police of documentation, those ghosts of past PT professors professing to know, from your notes, the level of your intent, skill, intelligence, care and effort that went into getting your patient better has only emerged since the early part of the 21st century.
Skilled therapy emerged from skilled nursing facilities where many people went following an acute hospitalization. Medicare began in 1965 as a program for treating acute, short-term medical problems for which a cure could be expected. For those persons, with 2-5 chronic conditions like...
- congestive heart failure
- obstructive pulmonary disease
- diabetes
- hypertension
- mental disorders
Often, there is no 'cure' for these conditions so Medicare mandated 'skilled therapy' as a way to ensure that certified professionals provided services and that patient safety was maintained.
Skilled Therapy and 'Progress'
Progress, the "improvement standard" so often unattainable in skilled nursing, is required in outpatient physical therapy. Getting and keeping people living independently keeps them in the lowest cost healthcare setting in America, their homes.
Nevertheless, local contractors have been criticized for applying an "improvement standard" as a way to deny needed care and save money...
"...for certain services, such as outpatient therapy services, Medicare's policies impose improvement standards that are inconsistent with the statute.An improvement standard in outpatient therapy clinics is less problematic today than it was when those words were written (2003). Today, about 48% of physical therapists use outcome measures - most of those are probably self-report measures like the...
The Medicare statute does not demand a showing of improvement to find services medically necessary or to cover treatment of an illness or an injury.
The statutory criterion for treatment of an illness or injury applies regardless of where the covered service is provided, be it in a skilled nursing facility, at home, or as an outpatient."
- OPTIMAL scale
- Oswestry scale
- Fear-Avoidance Beliefs scale
- Lower Extremity Functional scale
- Shoulder Pain and Disability scale
But, skilled therapy remains problematic.
Today, the search for 'skilled therapy' in PT notes and charts is an arbitrary scavenger hunt - paying off for auditors in daily notes when the PT is tired, busy, brief or vague.
Why not use specific evidence-based criteria: numbers, valid tests & measures, standardized outcomes and daily measurements centered on patient function?
I recommend physical therapists trade our allegiance to our 'old' practice patterns, based on observation and experience, for 'new' evidence based predictive models in exchange for immunity from the scourge of skilled therapy denials in Medicare audits.
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