Guest guest Posted January 31, 2007 Report Share Posted January 31, 2007 I can't negotiate that CMS website very well to give references but it is my understanding that if you rent space in a pool it must be solely used for your clients at the time. If there are two pools in the same room it would be OK to have exclusive use of that one while the other is being used for another purpose. Bettye -Saleh, PT Easter Seals TriCounties Ventura, CA ________________________________ From: PTManager on behalf of kpalma892 Sent: Wed 1/31/2007 14:11 To: PTManager Subject: pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2007 Report Share Posted January 31, 2007 I did more research and the clause re. this issue falls specifically under the PT services rendered in a private practice setting. I'm not sure if it would apply to OP hospital settings - anyone have any references? Kimberley R. Palma Office Manager - ECHN Rehabilitation Services Tel: x5579 Fax: _____ From: PTManager [mailto:PTManager ] On Behalf Of BettyeSaleh Sent: Wednesday, January 31, 2007 8:09 PM To: PTManager Subject: RE: pool therapy I can't negotiate that CMS website very well to give references but it is my understanding that if you rent space in a pool it must be solely used for your clients at the time. If there are two pools in the same room it would be OK to have exclusive use of that one while the other is being used for another purpose. Bettye -Saleh, PT Easter Seals TriCounties Ventura, CA ________________________________ From: PTManager <mailto:PTManager%40yahoogroups.com> on behalf of kpalma892 Sent: Wed 1/31/2007 14:11 To: PTManager <mailto:PTManager%40yahoogroups.com> Subject: pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2007 Report Share Posted January 31, 2007 If using a private/community pool and billing Medicare the following applies: (From Medicare Benefit Policy Manual: Pub 100-02, Chapter 15, Section 230.4 ) " Services should be furnished in the therapist's or group's office or in the patient's home. The office is defined as the location(s) where the practice is operated, in the state(s) where the therapist (and practice, if applicable) is legally authorized to furnish services, during the hours that the therapist engages in the practice at that location. If services are furnished in a private practice office space, that space shall be owned, leased, or rented by the practice and used for the exclusive purpose of operating the practice. For example, a therapist in private practice may furnish aquatic therapy in a community center pool. As required in other settings (such as rehabilitation agencies and CORFs), the practice would have to rent or lease the pool for those hours, and the use of the pool during that time would have to be restricted to the therapist's patients, in order to recognize the pool as part of the therapist's own practice office during those hours. " Pub 100-02 is readily available online at the Medicare website, and it is an Internet Only Manual. It is found on the CMS website - Medicare Section - Under the section on Regulation & Guidance. I would include the link, but yahoo always seem to truncate them on this list. Beckley Bloomingdale Consulting Group, Inc BloomingdaleConsulting.com <http://www.bloomingdaleconsulting.com/> (fax) _____ From: PTManager [mailto:PTManager ] On Behalf Of BettyeSaleh Sent: Wednesday, January 31, 2007 8:09 PM To: PTManager Subject: RE: pool therapy I can't negotiate that CMS website very well to give references but it is my understanding that if you rent space in a pool it must be solely used for your clients at the time. If there are two pools in the same room it would be OK to have exclusive use of that one while the other is being used for another purpose. Bettye -Saleh, PT Easter Seals TriCounties Ventura, CA ________________________________ From: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com on behalf of kpalma892 Sent: Wed 1/31/2007 14:11 To: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com Subject: pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted February 1, 2007 Report Share Posted February 1, 2007 It goes a bit further in our experience: is correct, for a hospital or private practice, the pool must be leased for exclusive use during the time the patients will be using it. Implied--and enforced in our state--is the fact that the pool is then part of the licensed hospital facility, and the state and/or JCAHO will inspect the leased space and make sure that it meets the physical and life/safety requirements of a hospital facility. Most of the pool facilities in our area would not meet the standards of those inspections; even " simple " things like signage requirements become major hurdles. Bob Perlson Director, Rehabilitation Services Asante Health System 781 Black Oak Dr. Ste 101 Medford Oregon pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted February 1, 2007 Report Share Posted February 1, 2007 , Was interested in your response. I had heard that the facility also had to be Medicare approved. Is that correct? (as it relates to a free standing fitness facility). Thank you DJ C. Julius PT, MA Service Delivery Leader, Ambulatory Rehab Services St. ph Mercy Hospital Michigan Orthopedic Center 5315 Elliott Drive, Suite 203 Ypsilanti, MI. 48197 Telephone Pager e-mail juliusd@... This e-mail is intended for the use of the individual or entity to which it is addressed and may contain information that is patient protected health information, privileged, confidential and/or exempt by law from disclosure. If the reader of this message and its attachments is not the intended recipient, any further dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication and attachments in error, please notify the sender noted immediately. After the notification, please delete the message and all attachments. Thank you for your anticipated cooperation. >>> nancy@... 1/31/2007 9:42 PM >>> If using a private/community pool and billing Medicare the following applies: (From Medicare Benefit Policy Manual: Pub 100-02, Chapter 15, Section 230.4 ) " Services should be furnished in the therapist's or group's office or in the patient's home. The office is defined as the location(s) where the practice is operated, in the state(s) where the therapist (and practice, if applicable) is legally authorized to furnish services, during the hours that the therapist engages in the practice at that location. If services are furnished in a private practice office space, that space shall be owned, leased, or rented by the practice and used for the exclusive purpose of operating the practice. For example, a therapist in private practice may furnish aquatic therapy in a community center pool. As required in other settings (such as rehabilitation agencies and CORFs), the practice would have to rent or lease the pool for those hours, and the use of the pool during that time would have to be restricted to the therapist's patients, in order to recognize the pool as part of the therapist's own practice office during those hours. " Pub 100-02 is readily available online at the Medicare website, and it is an Internet Only Manual. It is found on the CMS website - Medicare Section - Under the section on Regulation & Guidance. I would include the link, but yahoo always seem to truncate them on this list. Beckley Bloomingdale Consulting Group, Inc BloomingdaleConsulting.com <http://www.bloomingdaleconsulting.com/> (fax) _____ From: PTManager [mailto:PTManager ] On Behalf Of BettyeSaleh Sent: Wednesday, January 31, 2007 8:09 PM To: PTManager Subject: RE: pool therapy I can't negotiate that CMS website very well to give references but it is my understanding that if you rent space in a pool it must be solely used for your clients at the time. If there are two pools in the same room it would be OK to have exclusive use of that one while the other is being used for another purpose. Bettye -Saleh, PT Easter Seals TriCounties Ventura, CA ________________________________ From: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com on behalf of kpalma892 Sent: Wed 1/31/2007 14:11 To: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com Subject: pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted February 1, 2007 Report Share Posted February 1, 2007 Thanks Bob - I will echo that. One of my clients (rehab agency) in Florida added a therapy pool to her new clinic recently, and the State was involved in the entire process from construction on forward. In Florida there are differentiating rules for pools that are therapy pools including location. When I ran wheelchair sports programs in Oklahoma and Florida, we used community pools during 'open time' for wheelchair sports training and recreation, and during 'closed' time for therapy related activities that were billed, regardless of the payor. Beckley Bloomingdale Consulting Group, Inc ****************************************** BloomingdaleConsulting.com <http://www.bloomingdaleconsulting.com/> (fax) _____ From: PTManager [mailto:PTManager ] On Behalf Of Perlson, Bob Sent: Thursday, February 01, 2007 8:08 AM To: PTManager Subject: RE: pool therapy It goes a bit further in our experience: is correct, for a hospital or private practice, the pool must be leased for exclusive use during the time the patients will be using it. Implied--and enforced in our state--is the fact that the pool is then part of the licensed hospital facility, and the state and/or JCAHO will inspect the leased space and make sure that it meets the physical and life/safety requirements of a hospital facility. Most of the pool facilities in our area would not meet the standards of those inspections; even " simple " things like signage requirements become major hurdles. Bob Perlson Director, Rehabilitation Services Asante Health System 781 Black Oak Dr. Ste 101 Medford Oregon pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted February 1, 2007 Report Share Posted February 1, 2007 I am not aware of Medicare (CMS) requiring " Medicare approval " of a community pool. I have worked with many clinics getting ready for survey and certification as a CORF or Rehab Agency around the county, and many states have additional health regulations, code regulations, architectural regulations, etc that govern therapy clinics, and those vary depending on the type of Medicare certification you are trying to achieve. For example in California, a CORF requires compliance with different building code regulations than a Rehab Agency, in Alabama an architectural/building code review and inspection is required, etc. Since private practice clinics (PTPP/OTPP) are not surveyed by the State Agency as a requirement of Medicare Certification, some of these items may not be required for private practice. That is why it is important to review all the facility regulations pertinent to your State, Medicare certification category, Therapy Licensing Board (such as in Texas ), Medicare Contractor (carrier or FI), Certificate of Need requirements etc. Beckley Bloomingdale Consulting Group, Inc BloomingdaleConsulting.com <http://www.bloomingdaleconsulting.com/> (fax) _____ From: PTManager [mailto:PTManager ] On Behalf Of Doug Julius Sent: Thursday, February 01, 2007 9:35 AM To: PTManager Subject: RE: pool therapy , Was interested in your response. I had heard that the facility also had to be Medicare approved. Is that correct? (as it relates to a free standing fitness facility). Thank you DJ C. Julius PT, MA Service Delivery Leader, Ambulatory Rehab Services St. ph Mercy Hospital Michigan Orthopedic Center 5315 Elliott Drive, Suite 203 Ypsilanti, MI. 48197 Telephone Pager e-mail juliusd@trinity- <mailto:juliusd%40trinity-health.org> health.org This e-mail is intended for the use of the individual or entity to which it is addressed and may contain information that is patient protected health information, privileged, confidential and/or exempt by law from disclosure. If the reader of this message and its attachments is not the intended recipient, any further dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication and attachments in error, please notify the sender noted immediately. After the notification, please delete the message and all attachments. Thank you for your anticipated cooperation. >>> nancy@bloomingdalec <mailto:nancy%40bloomingdaleconsulting.com> onsulting.com 1/31/2007 9:42 PM >>> If using a private/community pool and billing Medicare the following applies: (From Medicare Benefit Policy Manual: Pub 100-02, Chapter 15, Section 230.4 ) " Services should be furnished in the therapist's or group's office or in the patient's home. The office is defined as the location(s) where the practice is operated, in the state(s) where the therapist (and practice, if applicable) is legally authorized to furnish services, during the hours that the therapist engages in the practice at that location. If services are furnished in a private practice office space, that space shall be owned, leased, or rented by the practice and used for the exclusive purpose of operating the practice. For example, a therapist in private practice may furnish aquatic therapy in a community center pool. As required in other settings (such as rehabilitation agencies and CORFs), the practice would have to rent or lease the pool for those hours, and the use of the pool during that time would have to be restricted to the therapist's patients, in order to recognize the pool as part of the therapist's own practice office during those hours. " Pub 100-02 is readily available online at the Medicare website, and it is an Internet Only Manual. It is found on the CMS website - Medicare Section - Under the section on Regulation & Guidance. I would include the link, but yahoo always seem to truncate them on this list. Beckley Bloomingdale Consulting Group, Inc BloomingdaleConsulting.com <http://www.blooming <http://www.bloomingdaleconsulting.com/> daleconsulting.com/> (fax) _____ From: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com [mailto:PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com] On Behalf Of BettyeSaleh Sent: Wednesday, January 31, 2007 8:09 PM To: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com Subject: RE: pool therapy I can't negotiate that CMS website very well to give references but it is my understanding that if you rent space in a pool it must be solely used for your clients at the time. If there are two pools in the same room it would be OK to have exclusive use of that one while the other is being used for another purpose. Bettye -Saleh, PT Easter Seals TriCounties Ventura, CA ________________________________ From: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com on behalf of kpalma892 Sent: Wed 1/31/2007 14:11 To: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com Subject: pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
Guest guest Posted February 6, 2007 Report Share Posted February 6, 2007 I spoke w/our intermediary - EMPIRE (for Connecticut). This policy pertains only to PT's practicing in a private practice setting (as noted in the manual) It does not apply to PT services rendered by a hospital outpatient dept. Kimberley R. Palma Office Manager - ECHN Rehabilitation Services Tel: x5579 Fax: _____ From: PTManager [mailto:PTManager ] On Behalf Of Doug Julius Sent: Thursday, February 01, 2007 9:35 AM To: PTManager Subject: RE: pool therapy , Was interested in your response. I had heard that the facility also had to be Medicare approved. Is that correct? (as it relates to a free standing fitness facility). Thank you DJ C. Julius PT, MA Service Delivery Leader, Ambulatory Rehab Services St. ph Mercy Hospital Michigan Orthopedic Center 5315 Elliott Drive, Suite 203 Ypsilanti, MI. 48197 Telephone Pager e-mail juliusd@... <mailto:juliusd%40trinity-health.org> This e-mail is intended for the use of the individual or entity to which it is addressed and may contain information that is patient protected health information, privileged, confidential and/or exempt by law from disclosure. If the reader of this message and its attachments is not the intended recipient, any further dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication and attachments in error, please notify the sender noted immediately. After the notification, please delete the message and all attachments. Thank you for your anticipated cooperation. >>> nancy@... <mailto:nancy%40bloomingdaleconsulting.com> 1/31/2007 9:42 PM >>> If using a private/community pool and billing Medicare the following applies: (From Medicare Benefit Policy Manual: Pub 100-02, Chapter 15, Section 230.4 ) " Services should be furnished in the therapist's or group's office or in the patient's home. The office is defined as the location(s) where the practice is operated, in the state(s) where the therapist (and practice, if applicable) is legally authorized to furnish services, during the hours that the therapist engages in the practice at that location. If services are furnished in a private practice office space, that space shall be owned, leased, or rented by the practice and used for the exclusive purpose of operating the practice. For example, a therapist in private practice may furnish aquatic therapy in a community center pool. As required in other settings (such as rehabilitation agencies and CORFs), the practice would have to rent or lease the pool for those hours, and the use of the pool during that time would have to be restricted to the therapist's patients, in order to recognize the pool as part of the therapist's own practice office during those hours. " Pub 100-02 is readily available online at the Medicare website, and it is an Internet Only Manual. It is found on the CMS website - Medicare Section - Under the section on Regulation & Guidance. I would include the link, but yahoo always seem to truncate them on this list. Beckley Bloomingdale Consulting Group, Inc BloomingdaleConsulting.com <http://www.bloomingdaleconsulting.com/ <http://www.bloomingdaleconsulting.com/> > (fax) _____ From: PTManager <mailto:PTManager%40yahoogroups.com> [mailto:PTManager <mailto:PTManager%40yahoogroups.com> ] On Behalf Of BettyeSaleh Sent: Wednesday, January 31, 2007 8:09 PM To: PTManager <mailto:PTManager%40yahoogroups.com> Subject: RE: pool therapy I can't negotiate that CMS website very well to give references but it is my understanding that if you rent space in a pool it must be solely used for your clients at the time. If there are two pools in the same room it would be OK to have exclusive use of that one while the other is being used for another purpose. Bettye -Saleh, PT Easter Seals TriCounties Ventura, CA ________________________________ From: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com on behalf of kpalma892 Sent: Wed 1/31/2007 14:11 To: PTManager@yahoogrou <mailto:PTManager%40yahoogroups.com> ps.com Subject: pool therapy Does anyone know where I can reference in Medicare Manuals any clause that prohibits the use of a fitness pool being used for both our clients and those in the fitness center. At one of our off-sites we lease pool time from the fitness center we are in thebuilding with. While we have a portion of the pool for limited time; club members can use the rest of the pool. I was reading in the APTA website a clause in CMS manuals stating we can only use those pools if we are alone in the pool with our patients. Is this true or only for private practice facilities? We are part of an outpatient hospital setting. thanks Kim Quote Link to comment Share on other sites More sharing options...
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