Re: OIG Report

[Guest guest]

Hi everyone,

Interesting report. I would hope that the APTA and the Private Practice

section have investigated this and determined if the therapists involved are

members or not. I think that if they are not members, it would be in the

interest of the organization to put out a statement distancing themselves

from them. I would imagine because of the size of the refund required, this

could make national news.

If they are members, then damage control would be helpful.

In my opinion, I would like to see the APTA develop a Director of

Communication position. There needs to be more visible response to both

positive and negative media involving physical therapy. For instance,

almost every year there are media reports of big research news coming out of

the AMA convention. How come we never see anything like this from the APTA

convention or about PT research at all??

The Director could handle things like this OIG report and make sure that the

public gets the truth about it. Just my humble opinion...

Tom Howell, P.T., M.P.T.

Howell Physical Therapy

Eagle, ID

howellpt@...

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OIG Report

List Serve,

Interesting report released by the OIG concerning

outpatient PT and OT provided by PCH Health Systems.

http://www.oig.hhs.gov/oas/reports/region9/90400069.pdf

Rick Gawenda, PT

HPA Government Affairs & Practice Committee

__________________________________________________

[Guest guest]

Rick,

I'd say a nearly $10million payback makes this a must read. Take note that the

significant errors found resulting in recovery was for failure of documentation,

including evidence the patient had visited their physician q30 days and the

demonstration of medical necessity.

, PT

Therapeutics

OIG Report

List Serve,

Interesting report released by the OIG concerning

outpatient PT and OT provided by PCH Health Systems.

http://www.oig.hhs.gov/oas/reports/region9/90400069.pdf

Rick Gawenda, PT

HPA Government Affairs & Practice Committee

__________________________________________________

[Guest guest]

Hello Tom,

Great idea! Has this been proposed to APTA in the past?

Either way, we should encourage our leadership to consider such a

position--which is crucial in today's world. A Director of Communication could

position

our profession well, give a good picture to others, and create a positive

sound for all to hear. We can all make a positive difference by sharing this

idea with any APTA Leaders that we know.

Thank you for sharing this great idea...maybe one day we can have an award

(The Tom Howell Award?) honoring a therapist that communicated our profession

most positively in the past year!

Bob Latz, PT, DPT

Florence, KY

[Guest guest]

Hi all

What I find very troubling in the report is that none of the claims was

substantiated. The largest portion of claims reportedly did not support being

Medically reasonable and necessary. Maybe I'm an optimist, but I would hope

that a portion of the claims would be found to be reasonable for coverage. I'm

also concerned about the reviews being too black and white and that the

human component of treatment is thrown into the garbage. The Medicare

population

is certainly not cut and dry and there are many times when their pace of

recovery is slower than I believe Medicare likes to cover, or " significant

recovery " is relative. I did not see a way of digging deeper into the claims

reviewed to see what they were basing decisions on, but I would bet we would

all

see some of our past clients and circumstances mirrored there. I think we

need to be very careful about condemning the therapists and figure out a way

to find out a little more about the process and the reviewers. There are two

sides to every story.

I wish everyone a great day

Vicki

Vicki Tilley PT,GCS

President

ElderFit In Home Rehab, North Carolina

(919) 644-6646

vicki@...

www.elderfitpt.com

In a message dated 7/24/2006 9:36:04 P.M. Eastern Standard Time,

DPT@... writes:

Rick,

I'd say a nearly $10million payback makes this a must read. Take note that

the significant errors found resulting in recovery was for failure of

documentation, including evidence the patient had visited their physician q30

days

and the demonstration of medical necessity.

, PT

Therapeutics

[Guest guest]

I don’t know the company but would agree on the surface that there may be a

technical issue at work. Maybe claims were not submitted with all requested

documentation, or there were massive billing technical issues. I am sure

it’s possible to have essentially 100% denials due to not following

prescription requirements, etc (we have seen examples of this with

non-traditional providers like school systems). I would suspect a technical

or bookkeeping error. I also suspect someone is feeling pretty stressed

right now about writing a 10 million check. Ouch I feel for them.

Steve Passmore PT

Healthy Recruiting Tools

HYPERLINK " mailto:spass@... " spass@...

_____

From: PTManager [mailto:PTManager ] On Behalf

Of VSTilley@...

Sent: Tuesday, July 25, 2006 7:18 AM

To: PTManager

Subject: Re: OIG Report

Hi all

What I find very troubling in the report is that none of the claims was

substantiated. The largest portion of claims reportedly did not support

being

Medically reasonable and necessary. Maybe I'm an optimist, but I would hope

that a portion of the claims would be found to be reasonable for coverage.

I'm

also concerned about the reviews being too black and white and that the

human component of treatment is thrown into the garbage. The Medicare

population

is certainly not cut and dry and there are many times when their pace of

recovery is slower than I believe Medicare likes to cover, or " significant

recovery " is relative. I did not see a way of digging deeper into the claims

reviewed to see what they were basing decisions on, but I would bet we would

all

see some of our past clients and circumstances mirrored there. I think we

need to be very careful about condemning the therapists and figure out a way

to find out a little more about the process and the reviewers. There are two

sides to every story.

I wish everyone a great day

Vicki

Vicki Tilley PT,GCS

President

ElderFit In Home Rehab, North Carolina

HYPERLINK " mailto:vicki%40elderfitpt.com " vickielderfitpt (DOT) -com

www.elderfitpt.-com

In a message dated 7/24/2006 9:36:04 P.M. Eastern Standard Time,

HYPERLINK " mailto:DPT%40aol.com " DPTaol (DOT) -com writes:

Rick,

I'd say a nearly $10million payback makes this a must read. Take note that

the significant errors found resulting in recovery was for failure of

documentation, including evidence the patient had visited their physician

q30 days

and the demonstration of medical necessity.

, PT

Therapeutics

[Guest guest]

Having worked for a Medicare Intermediary in my former life, I probably need

to weigh in on this issue a bit.

Times have changed and I don't know if procedures have changed or not

(someone else on the list might find something different than what I am about to

tell). Back in the late 80's, Mutual of Omaha (my employer) was under

subcontract

to HCFA (now known as CMS) to audit Hospitals, Physciatric Facilites and

Rehab Agencies. Whenever we did an audit, if we had potential fraud situation,

we

had to issue Management Comments to the Healthcare Facility and prove

financial damages over a certain dollar amount before something could be turned

over

to the OIG (unless it was an absolutely fraud). The Provider had to disregard

the Management comments for 2 consecutive years before we could turn the case

over to OIG.

While I don't know any more details than anyone else on this list, there was

a protocol at that time to follow before OIG became involved and usually a

pattern of disregard was demonstrated. Again, I don't know any more details

about this particular case than anyone else, but way back when, there was

definitely issues before anything ever made it to the OIG.

Jim Hall, CPA <///><

General Manager

Rehab Management Services, LLC

Cedar Rapids, IA

[Guest guest]

the sad part of this is that public needs to know this and put a stop to

this. We know of someone in our location who sent this article to our local

paper and asked them to publish it and it never happened. I am sure it was

they

did not want to offend any of those gold diggers. It is such a shame that we

all struggle to do what is right and we barely make it and then this report

comes out and they still keep doing the POPTS. Pardon my sarcasm, it has

been one of those weeks.

Bubba Klostermann OT, CVE, CEAS

CEO, WORK & REHAB

4546 South 14 th

Abilene, Texas 79605

phone:

fax:

email: bubklo@...

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[Guest guest]

If memory serves me correctly, the CMS/APTA agreement to require therapy

services provided by a physician to be under direct supervision of a licensed

therapist, was made public on November 3, 2004, so perhaps no current data is

available to prove that things have changed. The message below states " OIG

found that approximately 91 percent of physical therapy billed by physicians in

the first 6 months of 2002 did not meet program requirements " . I'm hoping this

is in part why a licensed therapist is now required. I've heard of lots of docs

who have closed down their PT because they can't find staff or don't want to pay

for it. That's great for business. Doug

Doug Sparks

Advanced Physical Therapy Concepts / APTC

www.aptc.biz<http://www.aptc.biz/>

doug@...

OIG Report

IG today posts three reports to the website. As

always, selecting the link immediately following the

report title will take you directly to the full

document.

Physical Therapy Billed by Physicians

(OEI-09-02-00200)

http://www.oig.hhs.gov/oei/reports/oei-09-02-00200.pdf<http://www.oig.hhsgov/oei\

/reports/oei-09-02-00200.pdf>

OIG found that approximately 91 percent of physical

therapy billed by physicians in the first 6 months of

2002 did not meet program requirements. These

inappropriately paid services cost the program and its

beneficiaries approximately $136 million. Because of

inadequate documentation, reviewers had difficulty

assessing the quality of the therapy services. In

addition, we identified aberrances in physicians'

billing patterns and unusually high volumes of claims

that suggest physical therapy is vulnerable to abuse.

Finally, physical therapy billed " incident to "

physicians' professional services and rendered by

unskilled and/or unlicensed personnel represent a

vulnerability that could be placing beneficiaries at

risk of receiving services that do not meet

professionally recognized standards of care. To

address these issues, we recommend CMS should consider

revisions, clarifications, and further study of the

" incident to " rule to ensure that Medicare

beneficiaries are recei!

ving skilled services from appropriately trained and

licensed staff and that the services meet

professionally recognized standards of care.

Rick Gawenda, PT

Director PM & R

Detroit Receiving Hospital

www.gawendaseminars.com<http://www.gawendaseminars.com/>

HPA Government Affairs & Practice Committee

__________________________________________________

[Guest guest]

Rick,

Startling statistic. Thank you for sharing it.

My understanding was that delivering PT with ' " unskilled " staff (anyone

other than PT or PTA) to Medicare patients was prohibited even with proper

documentation?

Joe Ruizch

Pueblo, CO

_____

From: PTManager [mailto:PTManager ] On Behalf

Of Agan,

Sent: Friday, August 25, 2006 1:49 PM

To: PTManager

Subject: RE: OIG Report

OIG Report

IG today posts three reports to the website. As

always, selecting the link immediately following the

report title will take you directly to the full

document.

Physical Therapy Billed by Physicians

(OEI-09-02-00200)

http://www.oig. <http://www.oig.hhs.gov/oei/reports/oei-09-02-00200.pdf>

hhs.gov/oei/reports/oei-09-02-00200.pdf

OIG found that approximately 91 percent of physical

therapy billed by physicians in the first 6 months of

2002 did not meet program requirements. These

inappropriately paid services cost the program and its

beneficiaries approximately $136 million. Because of

inadequate documentation, reviewers had difficulty

assessing the quality of the therapy services. In

addition, we identified aberrances in physicians'

billing patterns and unusually high volumes of claims

that suggest physical therapy is vulnerable to abuse.

Finally, physical therapy billed " incident to "

physicians' professional services and rendered by

unskilled and/or unlicensed personnel represent a

vulnerability that could be placing beneficiaries at

risk of receiving services that do not meet

professionally recognized standards of care. To

address these issues, we recommend CMS should consider

revisions, clarifications, and further study of the

" incident to " rule to ensure that Medicare

beneficiaries are recei!

ving skilled services from appropriately trained and

licensed staff and that the services meet

professionally recognized standards of care.

Rick Gawenda, PT

Director PM & R

Detroit Receiving Hospital

www.gawendaseminars.com

HPA Government Affairs & Practice Committee

__________________________________________________

[Guest guest]

Rick,

Interesting. Do you remember back in 1998 when the Medicare wedge audits were

performed on different aspects of the different disciplines of therapy; PT, OT,

and ST as part of Bill Clinton's BBA to review Medicare abuse? Our state was

one chosen for review of 10 charts which were Part A claims. If the audit found

" inappropriate billing " , the facility had to pay medicare back for the services.

Is this what medicare is imposing on the 91% of the claims they found here?

Would sound fair.

Matt Dvorak, PT

Yankton, SD

________________________________

From: PTManager on behalf of Agan,

Sent: Fri 8/25/2006 2:48 PM

To: PTManager

Subject: RE: OIG Report

OIG Report

IG today posts three reports to the website. As

always, selecting the link immediately following the

report title will take you directly to the full

document.

Physical Therapy Billed by Physicians

(OEI-09-02-00200)

http://www.oig.hhs.gov/oei/reports/oei-09-02-00200.pdf

<http://www.oig.hhs.gov/oei/reports/oei-09-02-00200.pdf>

OIG found that approximately 91 percent of physical

therapy billed by physicians in the first 6 months of

2002 did not meet program requirements. These

inappropriately paid services cost the program and its

beneficiaries approximately $136 million. Because of

inadequate documentation, reviewers had difficulty

assessing the quality of the therapy services. In

addition, we identified aberrances in physicians'

billing patterns and unusually high volumes of claims

that suggest physical therapy is vulnerable to abuse.

Finally, physical therapy billed " incident to "

physicians' professional services and rendered by

unskilled and/or unlicensed personnel represent a

vulnerability that could be placing beneficiaries at

risk of receiving services that do not meet

professionally recognized standards of care. To

address these issues, we recommend CMS should consider

revisions, clarifications, and further study of the

" incident to " rule to ensure that Medicare

beneficiaries are recei!

ving skilled services from appropriately trained and

licensed staff and that the services meet

professionally recognized standards of care.

Rick Gawenda, PT

Director PM & R

Detroit Receiving Hospital

www.gawendaseminars.com

HPA Government Affairs & Practice Committee

__________________________________________________