RE: Another IP Rehab question - groups

[Guest guest]

:

There is no specific reference under the Medicare standards. If your

PRO is InterQual, there is a restriction to 25% of the patient's time

that can be spent in group. Also, since IRF patients are being treated

in a Part A environment, we believe that it is appropriate to do

" concurrent therapy " under the Medicare Part A definition.

Angie , PT

President/CEO

Images & Associates

407 South Shore Drive

Amarillo, TX 79118

Phone-

Fax-

Mobile-

Web: www.ptconsultant.com

Email: images@...

Home of The Desktop Consultant: The Rehab Department's Guide to JCAHO

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Another IP Rehab question - groups

All the references I and our compliance people can find regarding PT,

OT, or ST groups are about outpatient. Does someone have references for

groups being utilized for IP Rehab under PPS?

That groups are OK? I guess that means, do the minutes in groups count?

thanks very much,

Jackins, P.T.

Manager

Physical Therapy/Exercise Training Center

University of Washington Medical Center

FAX

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[Guest guest]

Group treatment is allowed, but it has to be for the benefit of the patient,

not a facility practice. Group therapy has different regulations for Part A

and Part B.

Under Part A, all group participants must be doing the same task. And there

can’t be more than four patients per supervising therapist. During an

observation period, no more than 25 percent of the total time per discipline

can be claimed from group therapy as minutes of service in the MDS.

During this period, a patient must be receiving individual care to create a

RUG III payment level. If more than 25 percent of the total number of

minutes entered per discipline into the MDS come from group therapy then the

facility is violating therapy regulations. Also, the person who signs the

MDS as true and accurate can be charged with criminal activity for

falsifying of a federal document.

Also for Part A, providing group therapy must be identified in the plan of

care and therapy documentation. Although a therapy log isn’t mandated, it’s

highly recommended by Medicare and most Fiscal Intermediaries. This log must

show time spent in group activities, as well as individual treatment. Under

medical review, this practice would be investigated.

For Part B patients, all patients being treated in a group are billed the

group code, which isn’t a time sensitive unit. It’s not necessary for

participants to be performing the same treatment or activity. (A group is

two or more patients.) If you’re treating any other patient during the time

you providing direct care to a Part B patient, that Part B patient must have

services billed as group treatment codes.

In order to perform a Part B evaluation there must be documented evidence of

medical necessity, and Medicare is now pushing its long-standing requirement

that a physician see a patient before an evaluation order is issued.

It’s our belief that a percentage of patients who are residents of nursing

facilities should be receiving therapy services. And people who live in any

community have conditions that meet medical necessity requirements for

Medicare services. Don't go looking for Part B patients.

[Guest guest]

Noreen's response relates to SNF/skilled under RUGS - there are specific

regs for this.

For IP Rehab in an IRF, see my previous response.

Angie , PT

President/CEO

Images & Associates

407 South Shore Drive

Amarillo, TX 79118

Phone-

Fax-

Mobile-

Web: www.ptconsultant.com

Email: images@...

Home of The Desktop Consultant: The Rehab Department's Guide to JCAHO

NOTICE: This message and its attachments may contain confidential

information that is intended only for the use of the ADDRESSEE(s)named

above. If you are not the named addressee or if this message has been

addressed to you in error, you are directed not to read, disclose,

reproduce, distribute, disseminate or otherwise use this transmission.

Please notify the sender immediately by e-mail and delete and destroy

this message and its attachments.

RE: Another IP Rehab question - groups

Group treatment is allowed, but it has to be for the benefit of the

patient,

not a facility practice. Group therapy has different regulations for

Part A

and Part B.

Under Part A, all group participants must be doing the same task. And

there

can't be more than four patients per supervising therapist. During an

observation period, no more than 25 percent of the total time per

discipline

can be claimed from group therapy as minutes of service in the MDS.

During this period, a patient must be receiving individual care to

create a

RUG III payment level. If more than 25 percent of the total number of

minutes entered per discipline into the MDS come from group therapy then

the

facility is violating therapy regulations. Also, the person who signs

the

MDS as true and accurate can be charged with criminal activity for

falsifying of a federal document.

Also for Part A, providing group therapy must be identified in the plan

of

care and therapy documentation. Although a therapy log isn't mandated,

it's

highly recommended by Medicare and most Fiscal Intermediaries. This log

must

show time spent in group activities, as well as individual treatment.

Under

medical review, this practice would be investigated.

For Part B patients, all patients being treated in a group are billed

the

group code, which isn't a time sensitive unit. It's not necessary for

participants to be performing the same treatment or activity. (A group

is

two or more patients.) If you're treating any other patient during the

time

you providing direct care to a Part B patient, that Part B patient must

have

services billed as group treatment codes.

In order to perform a Part B evaluation there must be documented

evidence of

medical necessity, and Medicare is now pushing its long-standing

requirement

that a physician see a patient before an evaluation order is issued.

It's our belief that a percentage of patients who are residents of

nursing

facilities should be receiving therapy services. And people who live in

any

community have conditions that meet medical necessity requirements for

Medicare services. Don't go looking for Part B patients.

Looking to start your own Practice?

Visit www.InHomeRehab.com.

Bring PTManager to your organization or State Association with a

professional workshop or course - call us at 313 884-8920 to arrange

PTManager encourages participation in your professional association.

Join and participate now!

[Guest guest]

I think it is important for us to make the distinction between payment &

coverage requirements v. clinical need. Angie's point about groups in IRFs

is well-taken, because Medicare payment in this setting is primarily

function-based, not resource-based. In other words, while there is a time

requirement for minimum amount of needed therapy services as the basis for

admission (and coverage of the stay), payment is based upon the patient

status, not " minutes " .

What we may sometimes fail to recognize, however, is that definitions &

descriptions of " skilled " , reasonableness and necessity, cross all settings

covered under the Medicare program. Similarly, our professional standards &

legal standards do not distinguish between Medicare-certified settings, and

are universal. Therefore, if we base our decision to treat patient in a

group format solely on the basis of reimbursement concerns, we are placing

ourselves in a VERY vulnerable position.

If we allow reimbursement to drive practice, then our practice will diminish

along with reimbursement levels. I will reiterate a prior comment on this

subject: pilots refer to such a maneuver as a graveyard spiral.

Sources: IRF-PAI http://www.cms.hhs.gov/providers/irfpps/default.asp

APTA Summary of IRF Final Rule http://tinyurl.com/6xh87

http://www.apta.org/PT_Practice/ethics_pt/pro_conduct

Ken Mailly, PT

Mailly & Inglett Consulting, LLC

Tel. 973 692-0033

Fax 973 633-9557

68 Seneca Trail

Wayne, NJ, 07470

www.NJPTAid.biz

Bridging the Gap!

RE: Another IP Rehab question - groups

Group treatment is allowed, but it has to be for the benefit of the

patient,

not a facility practice. Group therapy has different regulations for

Part A

and Part B.

Under Part A, all group participants must be doing the same task. And

there

can't be more than four patients per supervising therapist. During an

observation period, no more than 25 percent of the total time per

discipline

can be claimed from group therapy as minutes of service in the MDS.

During this period, a patient must be receiving individual care to

create a

RUG III payment level. If more than 25 percent of the total number of

minutes entered per discipline into the MDS come from group therapy then

the

facility is violating therapy regulations. Also, the person who signs

the

MDS as true and accurate can be charged with criminal activity for

falsifying of a federal document.

Also for Part A, providing group therapy must be identified in the plan

of

care and therapy documentation. Although a therapy log isn't mandated,

it's

highly recommended by Medicare and most Fiscal Intermediaries. This log

must

show time spent in group activities, as well as individual treatment.

Under

medical review, this practice would be investigated.

For Part B patients, all patients being treated in a group are billed

the

group code, which isn't a time sensitive unit. It's not necessary for

participants to be performing the same treatment or activity. (A group

is

two or more patients.) If you're treating any other patient during the

time

you providing direct care to a Part B patient, that Part B patient must

have

services billed as group treatment codes.

In order to perform a Part B evaluation there must be documented

evidence of

medical necessity, and Medicare is now pushing its long-standing

requirement

that a physician see a patient before an evaluation order is issued.

It's our belief that a percentage of patients who are residents of

nursing

facilities should be receiving therapy services. And people who live in

any

community have conditions that meet medical necessity requirements for

Medicare services. Don't go looking for Part B patients.

Looking to start your own Practice?

Visit www.InHomeRehab.com.

Bring PTManager to your organization or State Association with a

professional workshop or course - call us at 313 884-8920 to arrange

PTManager encourages participation in your professional association.

Join and participate now!

[Guest guest]

I found this link for info on IRF... hope it helps

regulations covering IRF can be found in the Internet Only Manual (IOM)

Pub.100-2 Medicare Benefit Policy Manual at the Centers for Medicare and

Medicaid Services (CMS) Website at

www.cms.hhs.gov/manuals/pm_trans/R808HO.pdf Section 110 - Inpatient

Hospital Stays for Rehabilitation Care.

:

There is no specific reference under the Medicare standards. If your

PRO is InterQual, there is a restriction to 25% of the patient's time

that can be spent in group. Also, since IRF patients are being treated

in a Part A environment, we believe that it is appropriate to do

" concurrent therapy " under the Medicare Part A definition.

Angie , PT

President/CEO

Images & Associates

407 South Shore Drive

Amarillo, TX 79118

Phone-

Fax-

Mobile-

Web: www.ptconsultant.com

Email: images@...

Home of The Desktop Consultant: The Rehab Department's Guide to JCAHO

NOTICE: This message and its attachments may contain confidential

information that is intended only for the use of the ADDRESSEE(s)named

above. If you are not the named addressee or if this message has been

addressed to you in error, you are directed not to read, disclose,

reproduce, distribute, disseminate or otherwise use this transmission.

Please notify the sender immediately by e-mail and delete and destroy

this message and its attachments.

Another IP Rehab question - groups

All the references I and our compliance people can find regarding PT,

OT, or ST groups are about outpatient. Does someone have references for

groups being utilized for IP Rehab under PPS?

That groups are OK? I guess that means, do the minutes in groups count?

thanks very much,

Jackins, P.T.

Manager

Physical Therapy/Exercise Training Center

University of Washington Medical Center

FAX

Pager

Privileged, confidential or patient identifiable information may be

contained in this message. This information is meant only for the use of

the intended recipients. If you are not the intended recipient, or if

the message has been addressed to you in error, do not read, disclose,

reproduce, distribute, disseminate or otherwise use this transmission.

Instead, please notify the sender by reply email, and then destroy all

copies of the message and any attachments.

Looking to start your own Practice?

Visit www.InHomeRehab.com.

Bring PTManager to your organization or State Association with a

professional workshop or course - call us at 313 884-8920 to arrange

PTManager encourages participation in your professional association.

Join and participate now!