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Conference Name: An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes

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Continuing Education Documentation If CE’s are offered with this program, a separate link containing important information will be provided along with the pro- gram materials. Please follow the instructions in the CE documentation. presents . . . An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes

A 105-minute interactive audioconference

Wednesday, March 29, 2006

1:00 p.m.–2:45 p.m (Eastern) 12:00 p.m.–1:45 p.m. . (Central) 11:00 a.m.–12:45 p.m. (Mountain) 10:00 a.m.–11:45 a.m. (Pacific) In our materials we strive to provide our audience with useful, timely information. The live audioconference will follow the enclosed agenda. Occasionally our speakers will refer to the materials enclosed. We have noticed that other non-HCPro audioconference materials follow the speaker’s presentation bullet-by-bullet, page-by-page. Because our presentations are less rigid and rely more on speaker interaction, we do not include each speaker’s entire presentation. The materials contain helpful forms, crosswalks, policies, charts, and graphs. We hope that you find this information useful in the future.

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes The “An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes” audioconference materials package is published by HCPro, 200 Hoods Lane, P.O. Box 1168, Marblehead, MA 01945.

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 200 Hoods Lane P.O. Box 1168 Marblehead, MA 01945 Dear colleague, Tel: 800/650-6787 Fax: 800/639-8511 Thank you for participating in our “An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes” audioconference with Rick Gawenda, PT, and Ken Mailly, PT, moderated by Kevin Moschella. We are excited about the opportunity to interact with you directly and encourage you to take advantage of the opportunity to ask our experts your questions during the audioconference. If you would like to submit a question before the audioconference, please send it to [email protected] and provide the program date in the sub- ject line. We cannot guarantee your question will be answered during the program, but we will do our best to take a good cross-section of questions.

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Along with these audioconference materials, we have enclosed a fax eval- uation. We value your opinion. After the audioconference, please take a minute to complete the evaluation to let us know what you think.

Thanks again for working with us.

Best regards,

Shannon Tierney Audioconference coordinator Fax: 781/639-2982 E-mail: [email protected]

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes Contents

Agenda ...... vi

Speaker profiles ...... vii

Exhibit A ...... 1 Presentation by Rick Gawenda, PT, and Ken Mailly, PT

Exhibit B ...... 41 CCI Edits

Exhibit C ...... 44 Codes Frequently cited as “Problematic” by Payers

Exhibit D ...... 47 Claims Review Checklist

Resources ...... 49

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes Agenda

I. Identify new, deleted, and revised CPT codes for 2006

II. Identify problem CPT codes

III. Define group in various settings

IV. Define, identify, and understand CCI edits: Their application to all settings

V. Understand recent OIG audits concerning the misuse of modifier -59 and poor documentation

VI. Q&A

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes Speaker profiles

Kevin Moschella, moderator

Kevin Moschella is an editorial assistant at HCPro, Inc. He writes about issues of safety, security, infection control, rehabilitation, and finance.

Rick Gawenda, PT

Rick Gawenda graduated in 1991 with a Bachelor of Science in from Wayne State University in Detroit. Gawenda is currently director of physical medicine and rehabilitation at Detroit Receiving Hospital and owner of Gawenda Seminars. He has worked in all areas of therapy within the hospital setting and worked in home healthcare for five years. He has provided valuable education and consulting to both hospitals and his peers in the area of coding, billing, documentation, reimbursement, and the appeals process for Medicare denied claims. Gawenda’s Web site, www.gawendaseminars.com, provides a valuable source of information about rehabilitation rules and regulations, coding, documentation, and reimbursement.

Gawenda is on the editorial advisory board for ADVANCE for Directors In Rehabilitation and Briefings on Outpatient Rehab Reimbursement and Regulations. He is a member of the American College of Healthcare Executives, American Physical Therapy Association (APTA), Michigan Physical Therapy Association (MPTA), MPTA Insurance Policy Committee, and Program Committee of the Health Policy & Administration section of the APTA. Gawenda serves as the liaison between the MPTA and United Government Services, which is the Medicare fiscal intermediary for the state of Michigan.

Gawenda has provided his expertise for many articles in Briefings on Outpatient Rehab Reimbursement and Regulations and Eli’s Rehab Report on various topics, such as advance beneficiary notices, Medicare certification/recertification, the utilization of L codes as they relate to therapy, and the use of aides in therapy. In addition, he has written articles for ADVANCE for Directors in Rehabilitation about CPT coding, modifier -59, and the Medicare appeals process.

Ken Mailly, PT

Ken Mailly is a graduate of the State University of New York at Downstate Medical Center and is completing his master’s in public administration at Seton Hall University. For over 10 years, he has focused on issues related to healthcare policy and management.

In addition to his graduate studies, with well over 2,000 hours of continuing physical therapy education, Mailly has amassed an extremely diverse and extensive knowledge of the clinical practice of physical therapy. His primary clinical focus is on management of patients with bleeding and chronic soft-tissue disorders, and he is certified as an ergonomic specialist.

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes Along with this clinical knowledge base, Mailly has devoted the past eight years to the areas of regulation, legislation, and reimbursement of physical therapy services. He has served as an expert witness on behalf of both plaintiffs and defendants in numerous malpractice cases. He has also been consulted on state and fed- eral inquiries regarding physical therapy and rehabilitation billing and regulatory issues.

Mailly has served as a guest lecturer at Seton Hall University, University of Medicine and Dentistry of NJ, Richard Stockton College of NJ, Bergen Community College, and Mercer County College. He is also a fre- quent contributor and consultant for Advance, Eli’s Rehab Report, Briefings on Outpatient Regulation and Reimbursement, and Non-Physician Practitioner News. He has also been published in The Orthopedic Clinics of North America and featured in PT Magazine.

Mailly has been extensively involved in APTA at the local, state, and national levels for over 15 years. He has served APTA in various capacities, including delegate, professional affairs representative, and director of government relations. He has also served on the direct-access task force for APTA and serves, along with partner Barry Inglett, as a member consultant on coding initiatives and as a member of the APTA consulting service.

Mailly was also recently appointed to the Empire Medicare Services Provider Communications Advisory Group (PCOM) as a representative of physical therapists. He has presented during many state and national meetings and was the recipient of several professional awards, including being a two-time awardee of the APTA of NJ President’s Award. He is a member of the health policy and administration and private practice sections of APTA.

Mailly’s focus in the activities of M&I Consulting is on compliance with professional standards, state and fed- eral regulations, and management strategies.

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes Exhibit A

Presentation by Rick Gawenda, PT, and Ken Mailly, PT

1 EXHIBIT A

Coding & Billing for Rehab Services: Avoiding the Pitfalls of the 2006 Codes

Presented by: Rick Gawenda, PT & Ken Mailly, PT

1

Objectives

 Identify new, deleted, and revised CPT codes for 2006

 Identify problem CPT codes

 Define group therapy in various settings

2

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Objectives

 Define, identify, and understand CCI edits

 Define, identify, and understand when it is appropriate to use modifier-59 by therapists

 Be able to charge correctly for the services you provide – Understanding

Medicares “8” minute rule 3

CPT

A Closer Look

4

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Who can use them?

 Anyone whose legal scope of practice (qualified) permits the performance of the procedure described by the code.

 There are no PT, OT or SLP codes per se.

 Modifiers are used to describe who performed service  GN, GO, GP 5

Physical Medicine & Rehabilitation

97000 Level I Series CPT Codes

6

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Types of CPT Codes

 Time – Based codes

 Service – Based codes

7

Time Based Codes

 Requires direct one on one time spent with patient

 Contact is 15-120 minutes in length

 Can bill multiple units of the same time based CPT code on the same day per discipline per patient

8

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Service Based Codes

 Does not require direct one on one time with the patient

 Are un-timed

 Can only bill one unit of each service- based code daily per discipline per patient

9

Pre-Test #1 CVA Patient

 20 Minutes L/E strengthening

 20 Minutes NDT techniques to improve dynamic sitting and static standing balance

10

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Evaluations –Service Based

97001 Physical Therapy Evaluation

97002 Physical Therapy Re-Evaluation

97003 Evaluation

97004 Occupational Therapy Re-Evaluation

97005 Athletic Training Evaluation

97006 Athletic Training Re-Evaluation 11

Supervised Modalities

 The application of a modality that does not require direct (one on one) patient contact by provider.

 Un-timed (service-based)

 Once per session (date of service) per discipline per patient

 Includes CPT codes 97010-97028 12

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Constant Attendance

 The application of a modality that requires direct (one on one) patient contact by the provider

 Are time-based codes

 Can bill multiple units of these CPT codes to the same patient on the same day

 Includes CPT codes 97032-97039 13

Constant Attendance Modalities

97032 The application of a modality to one or more areas; electrical stimulation (manual), each 15 minutes 97033 Iontophoresis, each 15 minutes 97034 Contrast bath, each 15 minutes 97035 Ultrasound, each 15 minutes 97036 Hubbard tank, each 15 minutes 97039 Unlisted modality (specify type and time if constant attendance) 14

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G0283 or 97014 versus 97032

 Documentation in the patients medical record must clearly show that manual electrical stimulation was provided

 Types of manual electrical stimulation include hand-held units and ultrasound/electrical stimulation combination treatments

 Constant attendance may also involve visual and/or verbal contact with the patient during provision of the services (CPT Assistant July

2004) 15

Unlisted Modality - 97039

 May be supervised or constant attendance  Must specify type and time if constant attendance  Types of modalities billed using this code may include anodyne, light, laser, ice , and fluidotherapy if not billed under 97022

16

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Pre-Test #2 Low Back Patient

 15 Minutes Joint mobilizations and soft tissue mobilization

 17 Minutes and strengthening exs

 6 Minutes Ultrasound to low back

17

Therapeutic Procedures

 A manner of effecting change through the application of clinical skills and/or services that attempt to improve function.

 Therapist or therapist assistant required to have direct (one on one) patient contact.

 Therapist or therapist assistant must need to be one-on-one with the patient

 Includes CPT codes 97110-97140 and 97530-97762 18

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Exercise v. Activity

 : patient performing something that they would not normally perform in everyday life (CPT code 97110)

 Activity: patient IS performing something that they may be doing everyday, but with therapeutic intent (CPT Code 97530)

19

Critical points!

 Coding is as much about the intent of the activity, as it is the activity itself.

 e.g.: Electrical Stimulation

 BAPS

20

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The Biggie!!! 97150

21

97150

 Therapeutic procedure(s), group (2 or more individuals)

 Group therapy procedures involve constant attendance of the therapist or therapist assistant, but by definition do not require one-on-one patient contact by the provider.

 This code is un-timed. May only bill one unit per patient per discipline regardless of the amount of time the patient participated in the group 22

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Group Therapy-Medicare

 Patients need not be performing the same activity (Part B)  Patients must be working on the same activity (Part A)  Provider must be in constant attendance  Direct one-on-one contact not required  No limit of patients for Part B unless specified in LCD  Limited to 4 patients per group for Part A SNF setting  In SNF Part A setting, no more than 25% of the total minutes in a week per discipline may be in a group  Transmittal 1872, January 24, 2003 http://www.cms.hhs.gov/Transmittals/Downloads/R1872A3.pdf  Federal Register SNF Final Rule, July 30, 1999

 http://www.cms.hhs.gov/TherapyServices/ 23

Group Therapy or One-on-One

 What are the patients doing, but more importantly…

 What is the therapist or therapist assistant doing!

 Is the therapist or assistant in constant attendance with both patients or are they going back and forth between the patients spending one-on-one time with each patient in small increments 24

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SNF Part A Setting Concurrent Therapy

 Treating 2 or more patients during the same time period  Also known as dovetailing or supervisory therapy  Patients are performing different activities  Therapist can go back and forth between the patients  Key is the therapist or therapist is assistant is in the room, supervising the entire treatment process  Minutes for set up and preparing the patient for treatment may be counted  http://www.cms.hhs.gov/SNFPPS/Downloads/sbmanual112005-RUG53.pdf

 Page 3-72 to 3-76 25

Concurrent Therapy Case Example

 PT has Patient A beginning therapy at 9:00AM on a specific task  PT has Patient B beginning therapy at 9:15AM on a specific task different than Patient A  Treatment ends for each patient 30 minutes after it began.  PT is present the entire time with both patients  Each patient receives 30 minutes of one-on- one time on the MDS for that date of service 26

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SNF Part A or Part B Group Case Scenario

 SLP has 2 patients beginning therapy at 9:00AM and lasts until 9:45AM  Both patients work on activities to strengthen the tongue to move the bolus to the back of the mouth for swallowing for 25 minutes then  Work on lip strengthening exercises to keep the food in the mouth for 20 minutes  Both patients would receive 45 minutes billed as group treatment on the MDS for that date

of service or 1 unit 92508 if an outpatient 27

Wheelchair Management

 CPT code 97542  Now includes assessment, fitting, and training  Assessment includes, but is not limited to, determination of the patients need for a WC and type of WC required, patients strength and ROM, endurance, skin integrity, sitting balance, transfer ability, etc., measurements, and testing the patients ability with various chair functions.  Acknowledges “custom seating”.

 CPT Changes 2006-An Insiders View 28

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Orthotic Management & Prosthetic Management

 New heading added to the Medicine section of the CPT manual in 2006

 New heading includes CPT codes 97760 (formerly 97504), 97761 (formerly 97520), and 97762 (formerly 97703)

29

Orthotic Management & Prosthetic Management

 CPT code 97760 Orthotic(s) management and training (including assessment and fitting when not otherwise reported), upper extremity(s), lower extremity(s) and/or trunk, each 15 minutes

 This CPT code allows for reporting the assessment and management of a patient requiring a pre-fabricated or custom fabricated orthotic

30

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Orthotic Management & Prosthetic Management

 Orthotic management may include:  Assessing the patient  Determining the type of orthotic  Designing, selecting, and fabricating the orthotic  Orthotic training including exercises performed in the orthotic, instruction in skin care and wearing schedule 31

Orthotic Management & Prosthetic Management

 If you bill an “L” code for the pre-fabricated or custom fabricated orthotic, you may only bill the appropriate number of units of 97760 for the orthotic training based on the number of minutes spent providing the training

 The “L” code reimbursement includes the assessment, fabrication time, and fitting

 CPT Assistant December 2005

32

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 17 EXHIBIT A

97760 versus 97762

 97760 used for the assessment, fabrication, fitting, and training of an orthotic

 97762 used when adjustments need to made to an orthotic, orthotic needs to be modified or re-issued, etc.

33

New CPT Codes for 2006

98960 Education and training for patient self management by a qualified, non-physician healthcare professional using standardized curriculum, face-to-face with the patient (could include caregiver/family), each 30 minutes; individual patient

34

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New CPT Codes for 2006

98961 Education and training for patient self management by a qualified, non-physician healthcare professional using standardized curriculum, face-to-face with the patient (could include caregiver/family), each 30 minutes; 2-4 patients

35

New CPT Codes for 2006

98962 Education and training for patient self management by a qualified, non-physician healthcare professional using standardized curriculum, face-to-face with the patient (could include caregiver/family), each 30 minutes; 5-8 patients

36

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 19 EXHIBIT A

Education & Training Codes 98960 - 98962

 CMS not reimbursing for these CPT codes in 2006

 Does not necessarily affect PT, OT, or SLP services, in fact we are really not expected to be using these codes

 Whatever we are training the patient and/or caregiver in, those minutes are included/counted under the CPT code that best describes our treatment/intention 37

Pre-Test #3 Speech

 30 minutes strengthening exercises to improve voice communication

 15 minutes oromotor exercises to improve patients swallow

 15 minutes teaching the patient and their spouse in compensatory swallowing strategies

38

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Evaluations –Service Based

92506 Evaluation of speech, language, voice, communication, and/or auditory processing 92610 Evaluation of oral and pharyngeal swallowing function 92611 Motion fluoroscopic evaluation of swallowing function by cine or video recording 39

Speech Therapy Services

92507 Treatment of speech, language, voice,communication, and/or auditory processing disorder; individual

92508 Group, two or more individuals

92526 Treatment of swallowing dysfunction and/or oral function for feeding

40

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Speech Therapy CPT Codes Not To Be Used

 97110 Therapeutic exercise

 97112 Neuromuscular re-education

 CMS announced this during a SNF open door forum

 ASHA issued this announcement in November 2004 41

Speech Central Nervous System Assessments/Tests

96105 Assessment of aphasia (includes assessment of expressive and receptive speech and language function, language comprehension, speech production ability, reading, spelling, writing, eg, by Boston Diagnostic Aphasia Examination) with interpretation and report, per hour

42

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Speech Therapy Services

92526 Treatment of swallowing dysfunction and/or oral function for feeding

43

New Codes for SLP Services

92626 Evaluation of auditory rehabilitation status; 1 hour

92627 Evaluation of auditory rehabilitation status; each additional 15 minutes (list separately in addition to code for primary procedure

44

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 23 EXHIBIT A

New Codes for SLP Services

92630 Auditory rehabilitation; pre-lingual hearing loss 92633 Auditory rehabilitation; post- lingual hearing loss CMS not reimbursing for these CPT codes. If SLP provides these services, the minutes are billed under 92507. These services are not reimbursed if provided by an audiologist as Medicare only covers services that

are diagnostic in nature, not treatment. 45

National Correct Coding Initiative (NCCI) CCI Edits

 The Centers for Medicare and Medicaid Services (CMS) developed the National Correct Coding Initiative to promote national correct coding methodologies and to eliminate improper coding.

 CCI edits are developed based on coding conventions defined in the American Medical Association's Current Procedural Terminology (CPT) Manual, current standards of medical and surgical coding practice, input from specialty societies, and analysis of current coding practice. 46

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National Correct Coding Initiatives (NCCI)

 Initiated in 1996 to the private practice setting  Expanded to hospital outpatient departments in August 2000  Expanded to SNF Part B, CORFs, Rehab Agencies, and Home Health Agencies not under a Home Health Plan of Care on January 1, 2006  Current version is 12.0 for private practice and physician owned therapy clinics and 11.3

for all other settings 47

Modifiers

 In certain circumstances, specific CCI edits will be bypassed if required modifiers are present.

 The most commonly used modifier therapists utilize is modifier-59.

48

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Modifier - 59

 Distinct Procedural Service  Indicates that a procedure or service was distinct or independent from other services performed on the same day  Used to identify procedures/services that are not normally reported together, but are appropriate under the circumstances  Documentation must support use of modifier – 59 in that the procedures/services were provided at separate and distinct times, were medically necessary and required the skills of a therapist or therapist assistant under the supervision of a therapist 49

Modifier-59 Documentation Example

 9:00AM-9:30AM, aquatic therapy of (list what was provided), 9:45AM- 10:10AM, land-based exercises of (list what was provided)

 Aquatic therapy of (list what was provided) followed by land-based exercise of (list what was provided)

50

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CCI Edits

2 types of edits

1.) Mutually exclusive codes

2.) Column 1/Column 2 codes

51

Mutually Exclusive Codes

 Codes that cannot be billed together because they would not normally be performed together  Speech group (92508) and speech therapy treatment (92507)  Group therapy (97150) and therapeutic exercise (97110), neuromuscular re-education (97112), aquatic therapy (97113), or gait training (97116)  Mechanical traction (97012) and (97140)  Manual therapy (97140) and therapeutic Activities (97530) 52

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 27 EXHIBIT A

Column 1/Column 2 Codes

 Codes in which one of the codes is considered a component of a more comprehensive code on the bill

 Aquatic therapy (97113) and therapeutic exercise (97110)

 Therapeutic activities (97530) and gait training (97116)

 Therapeutic exercise (97110) and PT re-eval (97002) or OT re-eval (97004) 53

Column 1/Column 2 Codes

 Swallowing treatment (92526) and therapeutic exercise (97110)  Swallowing treatment (92526) and cognitive therapy (97532)  Swallowing treatment (92526) and Neuro re- education (97112)  Swallowing treatment (92526) and therapeutic activities (97530)  Swallowing treatment (92526) and unattended

e-stim (G0283) or manual e-stim (97032) 54

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CCI Edits

 Are applicable to one specific discipline of therapy billing different procedures on the same day that require modifier-59

 Are applicable when multiple disciplines of therapy occur to the same beneficiary on the same day billing procedures that require modifier-59

55

CCI Edit Example

 Pt receives 60 minutes of SLP treatment (92507) on 09/05/03

 Pt receives 30 minutes of therapeutic exercise (97110) and 30 minutes of gait training (97116) in PT on 09/05/03

 Pt receives OT consisting of 30 minutes of therapeutic activities (97530) and 30 minutes of Neuro Re-ed (97112) on 09/05/03 56

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An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 29 EXHIBIT A

CCI Edit Example

 By discipline, none of the procedures require modifier-59 to be reimbursed

 Since this patient was seen on the same day by more than one discipline, need to check between all disciplines (cross-check) as the need for modifier-59 does apply

 CMS billing system does not recognize therapy specific modifiers (GN, GO, GP) 57

CCI Edit Example

 Would need to append modifier-59 to 97110, 97112, 97116, and 97530

 Documentation would need to support that the services were performed at separate and distinct times

 Not appending modifier-59 in this example would cost you approximately $240 in lost reimbursement

58

30 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 30 EXHIBIT A

CCI Updates

 Updated quarterly

 www.gawendaseminars.com

 http://www.cms.hhs.gov/NationalCorrectCodI nitEd/

 Private practice and physician owned therapy clinics, click on NCCI Edits – physicians. All other settings, click on NCCI Edits - Hospital

59

“8 Minute Rule”

 Applies to direct contact CPT codes only  For any single CPT code, providers bill the appropriate number of units based on the time intervals on the next slide  If more than one CPT code is billed on a calendar day, then the total number of units that can be billed is constrained by the total treatment time. Do not count minutes of service-based CPT codes  Schedule on the next slide does not imply that any minute until the eighth should be excluded from the total count 60

Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes 31

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 31 EXHIBIT A

“8 Minute Rule”

 8 to < 23 1 unit  23 to < 38 2 units  38 to < 53 3 units  53 to < 68 4 units  68 to < 83 5 units  83 to < 98 6 units  98 to < 113 7 units

113 to < 128 8 units 61

“8” Minute Reference

 Medicare Claims Processing Manual, Chapter 5 – Part B Outpatient Rehabilitation and CORF Services, Section 20.2 and 20.3

http://www.cms.hhs.gov/manuals/downloads/clm104c05.pdf

62

32 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 32 EXHIBIT A

Pre-Test #1 CVA Patient

 20 Minutes L/E strengthening exercises

 20 Minutes NDT techniques to improve dynamic sitting and static standing balance

63

Post-Test #1

64

Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes 33

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 33 EXHIBIT A

Pre-Test #2 Low Back Patient

 15 Minutes Joint mobilizations and soft tissue mobilization

 17 Minutes Stretching and strengthening exs

 6 Minutes Ultrasound to low back

65

Post-Test #2

66

34 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 34 EXHIBIT A

Pre-Test #3 Speech

 30 minutes strengthening exercises to improve voice communication

 15 minutes oromotor exercises to improve patients swallow

 15 minutes teaching the patient and their spouse in compensatory swallowing strategies

67

Post-Test #3 Speech

68

Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes 35

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 35 EXHIBIT A

References

American Medical Association Current Procedural Terminology; CPT 2006; Standard Edition

Ingenix St. Anthony Publishing/Medicode Coding and Payment Guide for the Physical Therapist; 2006, 11th Edition

Ingenix St. Anthony Publishing/Medicode ICD-9-CM Expert for Hospitals-Volumes 1,2, & 3. 2005. 6th Edition

69

Essential References

 CPT-2005/6  https://webstore.ama-assn.org/index.jhtml  cpt Assistant

 CCI  http://www.cms.hhs.gov/NationalCorrectCodInitEd/

 APTA, AOTA, ASHA

 CMS Therapy Resources

 http://www.cms.hhs.gov/TherapyServices70/

36 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 36 EXHIBIT A

References for Billing Internet-Only Manuals

 www.cms.hhs.gov/Manuals

 Click on Internet-Only Manuals

 Click on Pub 100-4 Medicare Claims Processing Manual

 Choose the appropriate chapter depending on your setting

71

Billing References

 Chapter 5, Part B Outpatient Rehabilitation and CORF Services

 Chapter 6, SNF Inpatient Part A

 Chapter 7, SNF Part B

 Chapter 10, Home Health Agency

72

Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes 37

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 37 EXHIBIT A

 Ken Mailly, PT  Barry Inglett, PT, Cert MDT

68 Seneca Trail, Wayne, NJ, 07470 Tel: 973 692-0033 Fax: 973 633-9557 www.NJPTAid.biz 73

Mailly & Inglett Consulting

The mission of M&I is to promote and assist in the fair and equitable reimbursement for legitimate physical therapy services. In order to fulfill this mission, we have identified two major goals for both providers and payers respectively:

74

38 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 38 EXHIBIT A

Mailly & Inglett Consulting

1. Assist PTs and PTAs in improving the effectiveness and efficiency of their practice, regardless of setting, in a compliant manner. 2. Assist payers in recognizing and reimbursing for appropriate and legitimate care, while reducing improper payments and improper denials

75

Rick Gawenda, P.T.

 [email protected]

 [email protected]

 www.gawendaseminars.com

 (313) 745-3533

 (734) 717-1101

76

Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes 39

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 39 EXHIBIT A

Gawenda Seminars

 CPT and ICD-9 Coding

 Rehabilitation Documentation

 Medicare Appeals Process

 Consultation in the above

77

78

40 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 40 Exhibit B

CCI Edits

Source: Rick Gawenda, PT. Reprinted with permission. EXHIBIT B

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 42 EXHIBIT B

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 43 Exhibit C

Codes Frequently cited as “Problematic” by Payers

Source: Ken Mailly, PT. Reprinted with permission. EXHIBIT C

Codes Frequently cited as “Problematic” by Payers

95851: Range of motion measurements and report (separate procedure); each extremity (excluding hand) or each trunk section (spine)

• What are the Clinical Indications?

ROM measurements may be appropriate in cases where the major focus of treatment is on how motion may be changing in a joint over time. This is most often necessary in the presence of autoimmune diseases, such as RA, Lupus, or conditions such as OA. Such testing and reporting would be done very infrequently (such as monthly) and would include a report of each involved joint in an extremity. It would be inappropriate to do such testing in the vast majority of musculoskeletal conditions, where the focus of treatment would be on function rather than range of motion, and any impairment of joint ROM are secondary and temporary concerns. Furthermore, the billing of 95851 in such musculoskeletal cases may be an unbundling of the re-evaluation covered by 97002.

97112: Therapeutic procedure, one or more areas, each 15 minutes; neuromuscular reeducation of movement, balance, coordination, kinesthetic sense, posture, and/or for sitting and/or standing activities.

• What is this, and who can do this?

If a patient has a disorder of the central or peripheral nervous system, or a disturbance in nerve supply to peripheral musculature; strengthening alone may be ineffective is addressing a patient's functional limitations and physical impairment. This code would be commonly used in patients who may have suffered a , vestibular disorders, peripheral nerve injury, and other neurological con- ditions. It could also be justified by the presence of severe joint effusion causing reflex muscle inhi- bition, or in cases of severe joint sprain or other capsular damage causing proprioceptive impair- ments. In this case, it would only be appropriate until such time as the patient has recovered full & normal control of the motion involved.

As far as who may bill this code, the answer would be anyone that has the above activity covered within their legal scope of practice.

97530: Therapeutic activities, direct (one-on-one) patient contact by the provider (use of dynamic activities to improve functional performance), each 15 minutes

• Clarify the difference between this & 97110.

The critical piece in this code is the focus on “dynamic activities” and “functional performance”. This code would require that the patient is actually doing something that they could conceivably do in everyday life. Examples might be stepping up or down a curb, rising or sitting, lifting or pulling; with a focus on improving performance of these activities. The main focus of such activities might be to increase patient safety, or reducing the energy or effort required to perform them by improving the

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 45 EXHIBIT C quality of their movement. If the activities are being simply to improve the strength of the muscles or motion of the joints involved in performing the activity, 97110 would be more appropriate.

97535: Self-care/home management training (e.g., activities of daily living (ADL) and compensatory training, meal preparation, safety procedures, and instructions in use of devices/adaptive equipment) direct one-on-one contact by provider, each 15 minutes

• How many times per episode of care should this be billed?

Since this code is primarily focused on education and instruction (training), it would be most appro- priately used to teach, and check proper understanding of what has been taught. The documenta- tion would obviously also have to include the activity requiring training. Such education would typi- cally occur no more than 3-4 times, per episode of care. This frequency would obviously vary depending upon the total length of the episode, and the amount of change in clinical status that a patient may experience.

97026: infrared

• When would this normally be billed?

This supervised modality, classified as a heating modality, and would not normally be combined with other heating modalities in the same session. It is probably most often associated with treatment of integumentary diseases and disorders. Some payers may note increased utilization of this code in recent years, due to the manufacturing of “Near Infrared” and “Monochromatic Infrared” devices, which do not produce heat. Thus, these devices would likely not be most appropriately coded as 97026, but 97039, unlisted modality.

46 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

An Encore Presentation - Coding and Billing for Rehab Services: avoiding the pitfalls of the 2006 codes 46 Exhibit D

Claims Review Checklist

Source: Ken Mailly, PT. Reprinted with permission. EXHIBIT D

Claims Review Checklist I General 1. Did a PT perform the examination? 2. If claim is for Worker’s Comp, are findings and interventions related to compensable event? 3. Are interventions based on examination findings? 4. Do interventions comply with accepted standards of practice? 5. Is frequency and duration appropriate? 6. Were stated outcomes reached?

II Referral 1. If referral was made for PT, is it present in medical record? 2. If referrals were made for services other than PT, is follow-up documented?

III Record Review 1. Was intervention rendered with documented progress or goal attainment? 2. Did written report document the results of tests performed? 3. Did PT documentation follow APTA Guidelines for Physical Therapy Documentation and state law? 4. Was intervention record and documentation consistent with billing statement?

IV Modalities 1. Were local modalities continued unmodified for more than two weeks without evidence of improved condition? 2. Were palliative modalities limited to 6-8 weeks post injury? 3. If so, were they provided without any other intervention? 4. If more than 3 modalities were used daily, was appropriate justification included? 5. Does the intervention “fade” (decrease in frequency over time)? 6. If a medical device was used during intervention, was it FDA approved and therefore reimbursable?

V Provider Credentials 1. Are the credentials of provider included in the treatment record? 2. Is license number included as appropriate? 3. If PTA was involved in care, did they document such? 4. Is PTA documentation cosigned by a PT?

48 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes

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50 Coding and Billing for Rehab Services: Avoiding the pitfalls of the 2006 codes RESOURCES

Speaker resources

Rick Gawenda, PT Director, physical medicine and rehabilitation Detroit Receiving Hospital 4201 St. Antoine Blvd Detroit, MI 48201 Phone: 313/745-3533 Fax: 313/966-7664 E-mail: [email protected]

Ken Mailly, PT Mailly & Inglett Consulting, LLC 68 Seneca Trail Wayne, NJ 07470 Phone: 973/692-0033 Fax: 973/633-9557 E-mail: [email protected] Web site: www.NJPTAid.biz HCPro sites

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200 HoodsAn Lane, Encore P.O. Box Presentation 1168, Marblehead, - Coding MA 01945and Billing • tel 800/801-6661 for Rehab Services: • fax 800/738-1533 avoiding • e-mailthe pitfalls [email protected] of the 2006 codes • web www.greeley.com56