Re: Hosp-based Off-Site Outpatient Rehab Supervision

[Guest guest]

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We have

had many discussions with our Compliance Officer regarding this Medicare

regulation. We recently received an article from Health Law News by Hall Render

which stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational therapy

and speech therapy) because these services are not furnished by hospitals

" incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@...

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital-based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1@...<mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and intended

solely for the use of the individual

or entity to whom they are addressed. If you are not the intended recipient, you

are hereby notified

that any disclosure, copying, distribution or taking of any action in reliance

on the information contained in

this e-mail is prohibited. If you have received this e-mail in error, please

notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for your

consideration in this matter.

[Guest guest]

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We have

had many discussions with our Compliance Officer regarding this Medicare

regulation. We recently received an article from Health Law News by Hall Render

which stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational therapy

and speech therapy) because these services are not furnished by hospitals

" incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@...

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital-based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1@...<mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and intended

solely for the use of the individual

or entity to whom they are addressed. If you are not the intended recipient, you

are hereby notified

that any disclosure, copying, distribution or taking of any action in reliance

on the information contained in

this e-mail is prohibited. If you have received this e-mail in error, please

notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for your

consideration in this matter.

[Guest guest]

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We have

had many discussions with our Compliance Officer regarding this Medicare

regulation. We recently received an article from Health Law News by Hall Render

which stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational therapy

and speech therapy) because these services are not furnished by hospitals

" incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@...

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital-based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1@...<mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and intended

solely for the use of the individual

or entity to whom they are addressed. If you are not the intended recipient, you

are hereby notified

that any disclosure, copying, distribution or taking of any action in reliance

on the information contained in

this e-mail is prohibited. If you have received this e-mail in error, please

notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for your

consideration in this matter.

[Guest guest]

Thank you Sue! I've slogged through half a dozen articles regarding this topic

since I had never seen it before arriving here, but yours is the only one the

separates rehab services. Interestingly, I had even asked our Compliance

Officer to define " incident-to " the services of a physician but haven't gotten

anything back. Also, if you read through the rule, it states the physician not

only needs to be immediately available for emergencies, but needs to take over

the service if necessary! I have a high regard for physicians but can't imagine

most of them carrying out a therapy treatment plan.

Thank you again,

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Crossley,

Sent: Wednesday, November 11, 2009 4:00 PM

To: PTManager

Subject: RE: Hosp-based Off-Site Outpatient Rehab Supervision

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We have had

many discussions with our Compliance Officer regarding this Medicare regulation.

We recently received an article from Health Law News by Hall Render which

stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational therapy

and speech therapy) because these services are not furnished by hospitals

" incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@...<mailto:scrossley%40kentri.org><mailto:scrossley@...<\

mailto:scrossley%40kentri.org>>

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

[mailto:PTManager <mailto:PTManager%40yahoogroups.com>] On Behalf

Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital-based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1@...<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and intended

solely for the use of the individual

or entity to whom they are addressed. If you are not the intended recipient, you

are hereby notified

that any disclosure, copying, distribution or taking of any action in reliance

on the information contained in

this e-mail is prohibited. If you have received this e-mail in error, please

notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for your

consideration in this matter.

[Guest guest]

Thank you Sue! I've slogged through half a dozen articles regarding this topic

since I had never seen it before arriving here, but yours is the only one the

separates rehab services. Interestingly, I had even asked our Compliance

Officer to define " incident-to " the services of a physician but haven't gotten

anything back. Also, if you read through the rule, it states the physician not

only needs to be immediately available for emergencies, but needs to take over

the service if necessary! I have a high regard for physicians but can't imagine

most of them carrying out a therapy treatment plan.

Thank you again,

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Crossley,

Sent: Wednesday, November 11, 2009 4:00 PM

To: PTManager

Subject: RE: Hosp-based Off-Site Outpatient Rehab Supervision

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We have had

many discussions with our Compliance Officer regarding this Medicare regulation.

We recently received an article from Health Law News by Hall Render which

stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational therapy

and speech therapy) because these services are not furnished by hospitals

" incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@...<mailto:scrossley%40kentri.org><mailto:scrossley@...<\

mailto:scrossley%40kentri.org>>

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

[mailto:PTManager <mailto:PTManager%40yahoogroups.com>] On Behalf

Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital-based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1@...<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and intended

solely for the use of the individual

or entity to whom they are addressed. If you are not the intended recipient, you

are hereby notified

that any disclosure, copying, distribution or taking of any action in reliance

on the information contained in

this e-mail is prohibited. If you have received this e-mail in error, please

notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for your

consideration in this matter.

[Guest guest]

Thank you Sue! I've slogged through half a dozen articles regarding this topic

since I had never seen it before arriving here, but yours is the only one the

separates rehab services. Interestingly, I had even asked our Compliance

Officer to define " incident-to " the services of a physician but haven't gotten

anything back. Also, if you read through the rule, it states the physician not

only needs to be immediately available for emergencies, but needs to take over

the service if necessary! I have a high regard for physicians but can't imagine

most of them carrying out a therapy treatment plan.

Thank you again,

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Crossley,

Sent: Wednesday, November 11, 2009 4:00 PM

To: PTManager

Subject: RE: Hosp-based Off-Site Outpatient Rehab Supervision

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We have had

many discussions with our Compliance Officer regarding this Medicare regulation.

We recently received an article from Health Law News by Hall Render which

stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational therapy

and speech therapy) because these services are not furnished by hospitals

" incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@...<mailto:scrossley%40kentri.org><mailto:scrossley@...<\

mailto:scrossley%40kentri.org>>

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

[mailto:PTManager <mailto:PTManager%40yahoogroups.com>] On Behalf

Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital-based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1@...<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and intended

solely for the use of the individual

or entity to whom they are addressed. If you are not the intended recipient, you

are hereby notified

that any disclosure, copying, distribution or taking of any action in reliance

on the information contained in

this e-mail is prohibited. If you have received this e-mail in error, please

notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for your

consideration in this matter.

[Guest guest]

We are in the same position here - we are also paid through the PFS and

not through OPPS, and the federal register (if I recall correctly)

references this requirement for OPPS. Our corporate compliance officer

also supports this as well.

Kimberley R. Palma

Business Manager of Operations

Eastern Connecticut Health Network

T:

F:

Pager:

From: PTManager [mailto:PTManager ] On

Behalf Of Christen,

Sent: Wednesday, November 11, 2009 6:17 PM

To: PTManager

Subject: RE: Hosp-based Off-Site Outpatient Rehab

Supervision

Thank you Sue! I've slogged through half a dozen articles regarding this

topic since I had never seen it before arriving here, but yours is the

only one the separates rehab services. Interestingly, I had even asked

our Compliance Officer to define " incident-to " the services of a

physician but haven't gotten anything back. Also, if you read through

the rule, it states the physician not only needs to be immediately

available for emergencies, but needs to take over the service if

necessary! I have a high regard for physicians but can't imagine most of

them carrying out a therapy treatment plan.

Thank you again,

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

[mailto:PTManager <mailto:PTManager%40yahoogroups.com> ]

On Behalf Of Crossley,

Sent: Wednesday, November 11, 2009 4:00 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

Subject: RE: Hosp-based Off-Site Outpatient Rehab

Supervision

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We

have had many discussions with our Compliance Officer regarding this

Medicare regulation. We recently received an article from Health Law

News by Hall Render which stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational

therapy and speech therapy) because these services are not furnished by

hospitals " incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@... <mailto:scrossley%40kentri.org>

<mailto:scrossley%40kentri.org><mailto:scrossley@...

<mailto:scrossley%40kentri.org> <mailto:scrossley%40kentri.org>>

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com> [mailto:PTManager

<mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com>] On Behalf Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a

Medicare ruling in 2001. (In fact, she is following a discussion that

indicates the ruling was misinterpreted all this time and really means

that the physician must be in the room!) This apparently doesn't apply

to non-hospital-based outpatient centers, and any on-site centers are

assumed to have a physician in the Emergency Department. I have worked

in both the private practice and hospital arenas, including

hospital-based, off-site outpatient therapy centers and I've never heard

of this ruling before. In fact, many centers I'm aware of don't have a

physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do

you meet this requirement while still providing access for extended

hours (evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1@... <mailto:Kchristen1%40fhn.org>

<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and

intended solely for the use of the individual

or entity to whom they are addressed. If you are not the intended

recipient, you are hereby notified

that any disclosure, copying, distribution or taking of any action in

reliance on the information contained in

this e-mail is prohibited. If you have received this e-mail in error,

please notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for

your consideration in this matter.

[Guest guest]

We are in the same position here - we are also paid through the PFS and

not through OPPS, and the federal register (if I recall correctly)

references this requirement for OPPS. Our corporate compliance officer

also supports this as well.

Kimberley R. Palma

Business Manager of Operations

Eastern Connecticut Health Network

T:

F:

Pager:

From: PTManager [mailto:PTManager ] On

Behalf Of Christen,

Sent: Wednesday, November 11, 2009 6:17 PM

To: PTManager

Subject: RE: Hosp-based Off-Site Outpatient Rehab

Supervision

Thank you Sue! I've slogged through half a dozen articles regarding this

topic since I had never seen it before arriving here, but yours is the

only one the separates rehab services. Interestingly, I had even asked

our Compliance Officer to define " incident-to " the services of a

physician but haven't gotten anything back. Also, if you read through

the rule, it states the physician not only needs to be immediately

available for emergencies, but needs to take over the service if

necessary! I have a high regard for physicians but can't imagine most of

them carrying out a therapy treatment plan.

Thank you again,

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

[mailto:PTManager <mailto:PTManager%40yahoogroups.com> ]

On Behalf Of Crossley,

Sent: Wednesday, November 11, 2009 4:00 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

Subject: RE: Hosp-based Off-Site Outpatient Rehab

Supervision

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We

have had many discussions with our Compliance Officer regarding this

Medicare regulation. We recently received an article from Health Law

News by Hall Render which stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational

therapy and speech therapy) because these services are not furnished by

hospitals " incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@... <mailto:scrossley%40kentri.org>

<mailto:scrossley%40kentri.org><mailto:scrossley@...

<mailto:scrossley%40kentri.org> <mailto:scrossley%40kentri.org>>

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com> [mailto:PTManager

<mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com>] On Behalf Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a

Medicare ruling in 2001. (In fact, she is following a discussion that

indicates the ruling was misinterpreted all this time and really means

that the physician must be in the room!) This apparently doesn't apply

to non-hospital-based outpatient centers, and any on-site centers are

assumed to have a physician in the Emergency Department. I have worked

in both the private practice and hospital arenas, including

hospital-based, off-site outpatient therapy centers and I've never heard

of this ruling before. In fact, many centers I'm aware of don't have a

physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do

you meet this requirement while still providing access for extended

hours (evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1@... <mailto:Kchristen1%40fhn.org>

<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and

intended solely for the use of the individual

or entity to whom they are addressed. If you are not the intended

recipient, you are hereby notified

that any disclosure, copying, distribution or taking of any action in

reliance on the information contained in

this e-mail is prohibited. If you have received this e-mail in error,

please notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for

your consideration in this matter.

[Guest guest]

We are in the same position here - we are also paid through the PFS and

not through OPPS, and the federal register (if I recall correctly)

references this requirement for OPPS. Our corporate compliance officer

also supports this as well.

Kimberley R. Palma

Business Manager of Operations

Eastern Connecticut Health Network

T:

F:

Pager:

From: PTManager [mailto:PTManager ] On

Behalf Of Christen,

Sent: Wednesday, November 11, 2009 6:17 PM

To: PTManager

Subject: RE: Hosp-based Off-Site Outpatient Rehab

Supervision

Thank you Sue! I've slogged through half a dozen articles regarding this

topic since I had never seen it before arriving here, but yours is the

only one the separates rehab services. Interestingly, I had even asked

our Compliance Officer to define " incident-to " the services of a

physician but haven't gotten anything back. Also, if you read through

the rule, it states the physician not only needs to be immediately

available for emergencies, but needs to take over the service if

necessary! I have a high regard for physicians but can't imagine most of

them carrying out a therapy treatment plan.

Thank you again,

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

[mailto:PTManager <mailto:PTManager%40yahoogroups.com> ]

On Behalf Of Crossley,

Sent: Wednesday, November 11, 2009 4:00 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

Subject: RE: Hosp-based Off-Site Outpatient Rehab

Supervision

Hi ,

I work in a hospital based clinic, and we have an off-site facility. We

have had many discussions with our Compliance Officer regarding this

Medicare regulation. We recently received an article from Health Law

News by Hall Render which stated:

" CMS noted that the above requirements for therapeutic services are not

applicable to rehabilitation services (physical therapy, occupational

therapy and speech therapy) because these services are not furnished by

hospitals " incident to " the services of a physician. "

Crossley

Director, Therapy services

Kent Hospital

Warwick, RI

scrossley@... <mailto:scrossley%40kentri.org>

<mailto:scrossley%40kentri.org><mailto:scrossley@...

<mailto:scrossley%40kentri.org> <mailto:scrossley%40kentri.org>>

________________________________

From: PTManager <mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com> [mailto:PTManager

<mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com>] On Behalf Of

Sent: Wednesday, November 11, 2009 4:01 PM

To: PTManager <mailto:PTManager%40yahoogroups.com>

<mailto:PTManager%40yahoogroups.com>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a

Medicare ruling in 2001. (In fact, she is following a discussion that

indicates the ruling was misinterpreted all this time and really means

that the physician must be in the room!) This apparently doesn't apply

to non-hospital-based outpatient centers, and any on-site centers are

assumed to have a physician in the Emergency Department. I have worked

in both the private practice and hospital arenas, including

hospital-based, off-site outpatient therapy centers and I've never heard

of this ruling before. In fact, many centers I'm aware of don't have a

physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do

you meet this requirement while still providing access for extended

hours (evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1@... <mailto:Kchristen1%40fhn.org>

<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential and

intended solely for the use of the individual

or entity to whom they are addressed. If you are not the intended

recipient, you are hereby notified

that any disclosure, copying, distribution or taking of any action in

reliance on the information contained in

this e-mail is prohibited. If you have received this e-mail in error,

please notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you for

your consideration in this matter.

[Guest guest]

So can a POPTS have a physician-owned PT practice that is in a separate

building without the physician being present in that building? Is there

a distance requirement? Does the physician on site have to be the one

who owns them? Are there any links to CMS that explains this clearly?

There are a few POPTS in our area that are really questionable in this

regard... would enjoy stirring the pot a bit.

Meryl W. Freeman, MS PT

Manager, OP Rehab

Rex Healthcare

Raleigh, NC

Hosp-based Off-Site Outpatient Rehab

Supervision

Hello Group,

I've recently joined a health system which includes one

hospital-based, off-site outpatient physical and occupational therapy

clinic. I've been informed by our Risk manager that Medicare requires

on-site physician supervision, meaning that a physician must be in the

building whenever a Medicare client is seen for therapy. According to

her, this was a Medicare ruling in 2001. (In fact, she is following a

discussion that indicates the ruling was misinterpreted all this time

and really means that the physician must be in the room!) This

apparently doesn't apply to non-hospital-based outpatient centers, and

any on-site centers are assumed to have a physician in the Emergency

Department. I have worked in both the private practice and hospital

arenas, including hospital-based, off-site outpatient therapy centers

and I've never heard of this ruling before. In fact, many centers I'm

aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so,

how do you meet this requirement while still providing access for

extended hours (evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard

anything.

Any feedback is appreciated! I do have copies (pdf files) of

letters discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1@... <mailto:Kchristen1%40fhn.org>

<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential

and intended solely for the use of the individual

or entity to whom they are addressed. If you are not the

intended recipient, you are hereby notified

that any disclosure, copying, distribution or taking of any

action in reliance on the information contained in

this e-mail is prohibited. If you have received this e-mail in

error, please notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you

for your consideration in this matter.

[Guest guest]

So can a POPTS have a physician-owned PT practice that is in a separate

building without the physician being present in that building? Is there

a distance requirement? Does the physician on site have to be the one

who owns them? Are there any links to CMS that explains this clearly?

There are a few POPTS in our area that are really questionable in this

regard... would enjoy stirring the pot a bit.

Meryl W. Freeman, MS PT

Manager, OP Rehab

Rex Healthcare

Raleigh, NC

Hosp-based Off-Site Outpatient Rehab

Supervision

Hello Group,

I've recently joined a health system which includes one

hospital-based, off-site outpatient physical and occupational therapy

clinic. I've been informed by our Risk manager that Medicare requires

on-site physician supervision, meaning that a physician must be in the

building whenever a Medicare client is seen for therapy. According to

her, this was a Medicare ruling in 2001. (In fact, she is following a

discussion that indicates the ruling was misinterpreted all this time

and really means that the physician must be in the room!) This

apparently doesn't apply to non-hospital-based outpatient centers, and

any on-site centers are assumed to have a physician in the Emergency

Department. I have worked in both the private practice and hospital

arenas, including hospital-based, off-site outpatient therapy centers

and I've never heard of this ruling before. In fact, many centers I'm

aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so,

how do you meet this requirement while still providing access for

extended hours (evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard

anything.

Any feedback is appreciated! I do have copies (pdf files) of

letters discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1@... <mailto:Kchristen1%40fhn.org>

<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential

and intended solely for the use of the individual

or entity to whom they are addressed. If you are not the

intended recipient, you are hereby notified

that any disclosure, copying, distribution or taking of any

action in reliance on the information contained in

this e-mail is prohibited. If you have received this e-mail in

error, please notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you

for your consideration in this matter.

[Guest guest]

So can a POPTS have a physician-owned PT practice that is in a separate

building without the physician being present in that building? Is there

a distance requirement? Does the physician on site have to be the one

who owns them? Are there any links to CMS that explains this clearly?

There are a few POPTS in our area that are really questionable in this

regard... would enjoy stirring the pot a bit.

Meryl W. Freeman, MS PT

Manager, OP Rehab

Rex Healthcare

Raleigh, NC

Hosp-based Off-Site Outpatient Rehab

Supervision

Hello Group,

I've recently joined a health system which includes one

hospital-based, off-site outpatient physical and occupational therapy

clinic. I've been informed by our Risk manager that Medicare requires

on-site physician supervision, meaning that a physician must be in the

building whenever a Medicare client is seen for therapy. According to

her, this was a Medicare ruling in 2001. (In fact, she is following a

discussion that indicates the ruling was misinterpreted all this time

and really means that the physician must be in the room!) This

apparently doesn't apply to non-hospital-based outpatient centers, and

any on-site centers are assumed to have a physician in the Emergency

Department. I have worked in both the private practice and hospital

arenas, including hospital-based, off-site outpatient therapy centers

and I've never heard of this ruling before. In fact, many centers I'm

aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so,

how do you meet this requirement while still providing access for

extended hours (evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard

anything.

Any feedback is appreciated! I do have copies (pdf files) of

letters discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1@... <mailto:Kchristen1%40fhn.org>

<mailto:Kchristen1%40fhn.org><mailto:Kchristen1%40fhn.org>

Director of Rehabilitation Services

FHN

Freeport, IL

________________________________

This e-mail and any files transmitted with it are confidential

and intended solely for the use of the individual

or entity to whom they are addressed. If you are not the

intended recipient, you are hereby notified

that any disclosure, copying, distribution or taking of any

action in reliance on the information contained in

this e-mail is prohibited. If you have received this e-mail in

error, please notify sender by reply e-mail and

delete this message and any attachment(s) immediately. Thank you

for your consideration in this matter.

[Guest guest]

,

The APTA just released information regarding the OPPS final rule that clarifies

the supervision requirements in OP hospital departments via their online

bulletin (11/13/09) as follows:

In the 2010 Outpatient Prospective Payment System (OPPS) Final Rule, issued

October 30, the Centers for Medicare and Medicaid Services (CMS) confirms that

physical therapy services delivered in an outpatient hospital department do not

require the direct supervision of a physician. The OPPS is the method of payment

for most services delivered in an outpatient hospital department. However,

physical therapy services are considered a separate benefit covered under the

Medicare physician fee schedule through the Part B benefit. Therefore, they do

not fall under the therapeutic services category that requires direct physician

supervision under the OPPS.

 

, NY

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager

Date: Wednesday, November 11, 2009, 9:00 PM

 

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

,

Does this mean that ALL hospital based outpatient physicial therapy will be

subjected to the Medicare Cap of $1840 combined with speech therapy like all

other outpatient physical therapy providers? or only those billing under Part B.

Jill Sedmak, PT, MSPT, ATC

Director of therapy services

Associated Orthopedists of Detroit, P.C.

Shelby Twp, MI

From: <KChristen1fhn (DOT) org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

 

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Hospital-based Outpatient therapy departments have never been subject to the

Medicare Cap.

Not to say that this couldn’t change sometime.

Dan , PT

PT Manager

Vernon Memorial Hospital

Viroqua, WI 54665

dnelson@...

From: PTManager [mailto:PTManager ] On Behalf Of

AOD Physical Therapy

Sent: Monday, November 16, 2009 11:55 AM

To: PTManager

Subject: Re: Hosp-based Off-Site Outpatient Rehab Supervision

,

Does this mean that ALL hospital based outpatient physicial therapy will be

subjected to the Medicare Cap of $1840 combined with speech therapy like all

other outpatient physical therapy providers? or only those billing under Part B.

Jill Sedmak, PT, MSPT, ATC

Director of therapy services

Associated Orthopedists of Detroit, P.C.

Shelby Twp, MI

From: <KChristen1fhn (DOT) org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Hospital-based Outpatient therapy departments have never been subject to the

Medicare Cap.

Not to say that this couldn’t change sometime.

Dan , PT

PT Manager

Vernon Memorial Hospital

Viroqua, WI 54665

dnelson@...

From: PTManager [mailto:PTManager ] On Behalf Of

AOD Physical Therapy

Sent: Monday, November 16, 2009 11:55 AM

To: PTManager

Subject: Re: Hosp-based Off-Site Outpatient Rehab Supervision

,

Does this mean that ALL hospital based outpatient physicial therapy will be

subjected to the Medicare Cap of $1840 combined with speech therapy like all

other outpatient physical therapy providers? or only those billing under Part B.

Jill Sedmak, PT, MSPT, ATC

Director of therapy services

Associated Orthopedists of Detroit, P.C.

Shelby Twp, MI

From: <KChristen1fhn (DOT) org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Hospital-based Outpatient therapy departments have never been subject to the

Medicare Cap.

Not to say that this couldn’t change sometime.

Dan , PT

PT Manager

Vernon Memorial Hospital

Viroqua, WI 54665

dnelson@...

From: PTManager [mailto:PTManager ] On Behalf Of

AOD Physical Therapy

Sent: Monday, November 16, 2009 11:55 AM

To: PTManager

Subject: Re: Hosp-based Off-Site Outpatient Rehab Supervision

,

Does this mean that ALL hospital based outpatient physicial therapy will be

subjected to the Medicare Cap of $1840 combined with speech therapy like all

other outpatient physical therapy providers? or only those billing under Part B.

Jill Sedmak, PT, MSPT, ATC

Director of therapy services

Associated Orthopedists of Detroit, P.C.

Shelby Twp, MI

From: <KChristen1fhn (DOT) org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Jill -

It doesn't address the cap. It says that hospitals' outpatient PT

departments are paid under the Medicare Physician Fee Schedule, just as

physician services are.

So, it says that hospital outpatient PT does not require a physician

presence to be covered, such as the " ancillary departments " like xray, lab,

and cardiac rehab do.

This is appropriate: PT is more like a physician practice.

Regards,

Dick Hillyer, PT,DPT,MBA,MSM

Dr. W. Hillyer

Hillyer Consulting

Cape Coral, FL 33914

_____

From: PTManager [mailto:PTManager ] On Behalf

Of AOD Physical Therapy

Sent: Monday, November 16, 2009 12:55 PM

To: PTManager

Subject: Re: Hosp-based Off-Site Outpatient Rehab Supervision

,

Does this mean that ALL hospital based outpatient physicial therapy will be

subjected to the Medicare Cap of $1840 combined with speech therapy like all

other outpatient physical therapy providers? or only those billing under

Part B.

Jill Sedmak, PT, MSPT, ATC

Director of therapy services

Associated Orthopedists of Detroit, P.C.

Shelby Twp, MI

From: <KChristen1fhn (DOT) org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a Medicare

ruling in 2001. (In fact, she is following a discussion that indicates the

ruling was misinterpreted all this time and really means that the physician

must be in the room!) This apparently doesn't apply to non-hospital- based

outpatient centers, and any on-site centers are assumed to have a physician

in the Emergency Department. I have worked in both the private practice and

hospital arenas, including hospital-based, off-site outpatient therapy

centers and I've never heard of this ruling before. In fact, many centers

I'm aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you

meet this requirement while still providing access for extended hours

(evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Jill,

I have never heard that the caps will apply to hospital outpatient therapy

settings.  Perhaps some day they will.

NY

From: <KChristen1@ fhn. org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

 

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Jill,

I have never heard that the caps will apply to hospital outpatient therapy

settings.  Perhaps some day they will.

NY

From: <KChristen1@ fhn. org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

 

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Jill,

I have never heard that the caps will apply to hospital outpatient therapy

settings.  Perhaps some day they will.

NY

From: <KChristen1@ fhn. org>

Subject: Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

 

Hello Group,

I've recently joined a health system which includes one hospital-based, off-site

outpatient physical and occupational therapy clinic. I've been informed by our

Risk manager that Medicare requires on-site physician supervision, meaning that

a physician must be in the building whenever a Medicare client is seen for

therapy. According to her, this was a Medicare ruling in 2001. (In fact, she is

following a discussion that indicates the ruling was misinterpreted all this

time and really means that the physician must be in the room!) This apparently

doesn't apply to non-hospital- based outpatient centers, and any on-site centers

are assumed to have a physician in the Emergency Department. I have worked in

both the private practice and hospital arenas, including hospital-based,

off-site outpatient therapy centers and I've never heard of this ruling before.

In fact, many centers I'm aware of don't have a physician for miles. My

questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you meet

this requirement while still providing access for extended hours (evenings,

weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters discussing

the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Sorry to show my ignorance and lack of understanding, but what is the logic

behind placing a cap on private practices and not imposing them on hospital

based PT? The same thing goes for Medicaid not reimbursing for treatment of

anyone over 21 years of age in private practice but then paying if they are

treated by the same PT in a hospital based department- what's the reasoning?

Hill, PT, DPT

Meridian, MS

Sent via BlackBerry by AT & T

Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a Medicare

ruling in 2001. (In fact, she is following a discussion that indicates the

ruling was misinterpreted all this time and really means that the physician

must be in the room!) This apparently doesn't apply to non-hospital- based

outpatient centers, and any on-site centers are assumed to have a physician

in the Emergency Department. I have worked in both the private practice and

hospital arenas, including hospital-based, off-site outpatient therapy

centers and I've never heard of this ruling before. In fact, many centers

I'm aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you

meet this requirement while still providing access for extended hours

(evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

Sorry to show my ignorance and lack of understanding, but what is the logic

behind placing a cap on private practices and not imposing them on hospital

based PT? The same thing goes for Medicaid not reimbursing for treatment of

anyone over 21 years of age in private practice but then paying if they are

treated by the same PT in a hospital based department- what's the reasoning?

Hill, PT, DPT

Meridian, MS

Sent via BlackBerry by AT & T

Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a Medicare

ruling in 2001. (In fact, she is following a discussion that indicates the

ruling was misinterpreted all this time and really means that the physician

must be in the room!) This apparently doesn't apply to non-hospital- based

outpatient centers, and any on-site centers are assumed to have a physician

in the Emergency Department. I have worked in both the private practice and

hospital arenas, including hospital-based, off-site outpatient therapy

centers and I've never heard of this ruling before. In fact, many centers

I'm aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you

meet this requirement while still providing access for extended hours

(evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

:

I don't think your statement shows any sign of ignorance. On the contrary: a

lot of common sense.

Hospitals will lobby/fight for their profits off PT. And so will the nursing

homes/SNF; Rehab centers; Home health agencies, etc. In other words, all the

businesses that profit from physical therapists. Hence, the myriad of different

regulations we are posed with, including how and who we supervise, how much we

get paid for the same exact services we provide etc etc.

PTs in private practice stand alone, backed by no one but themselves

(ourselves). Not a powerful place to be. That is, unless we would get

organized politically (which is like wrangling stary cats, if you know what I

mean). But unless we do, the business model of physiotherapists in private

practice will soon be extinct.

Sincerely;

Armin Loges, PT

Tampa, FL

From: hilljeremy@...

Sent: Monday, November 16, 2009 8:49 PM

To: PTManager

Subject: Re: Hosp-based Off-Site Outpatient Rehab Supervision

Sorry to show my ignorance and lack of understanding, but what is the logic

behind placing a cap on private practices and not imposing them on hospital

based PT? The same thing goes for Medicaid not reimbursing for treatment of

anyone over 21 years of age in private practice but then paying if they are

treated by the same PT in a hospital based department- what's the reasoning?

Hill, PT, DPT

Meridian, MS

Sent via BlackBerry by AT & T

Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a Medicare

ruling in 2001. (In fact, she is following a discussion that indicates the

ruling was misinterpreted all this time and really means that the physician

must be in the room!) This apparently doesn't apply to non-hospital- based

outpatient centers, and any on-site centers are assumed to have a physician

in the Emergency Department. I have worked in both the private practice and

hospital arenas, including hospital-based, off-site outpatient therapy

centers and I've never heard of this ruling before. In fact, many centers

I'm aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you

meet this requirement while still providing access for extended hours

(evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL

[Guest guest]

:

I don't think your statement shows any sign of ignorance. On the contrary: a

lot of common sense.

Hospitals will lobby/fight for their profits off PT. And so will the nursing

homes/SNF; Rehab centers; Home health agencies, etc. In other words, all the

businesses that profit from physical therapists. Hence, the myriad of different

regulations we are posed with, including how and who we supervise, how much we

get paid for the same exact services we provide etc etc.

PTs in private practice stand alone, backed by no one but themselves

(ourselves). Not a powerful place to be. That is, unless we would get

organized politically (which is like wrangling stary cats, if you know what I

mean). But unless we do, the business model of physiotherapists in private

practice will soon be extinct.

Sincerely;

Armin Loges, PT

Tampa, FL

From: hilljeremy@...

Sent: Monday, November 16, 2009 8:49 PM

To: PTManager

Subject: Re: Hosp-based Off-Site Outpatient Rehab Supervision

Sorry to show my ignorance and lack of understanding, but what is the logic

behind placing a cap on private practices and not imposing them on hospital

based PT? The same thing goes for Medicaid not reimbursing for treatment of

anyone over 21 years of age in private practice but then paying if they are

treated by the same PT in a hospital based department- what's the reasoning?

Hill, PT, DPT

Meridian, MS

Sent via BlackBerry by AT & T

Hosp-based Off-Site Outpatient Rehab Supervision

To: PTManager@yahoogrou ps.com

Date: Wednesday, November 11, 2009, 9:00 PM

Hello Group,

I've recently joined a health system which includes one hospital-based,

off-site outpatient physical and occupational therapy clinic. I've been

informed by our Risk manager that Medicare requires on-site physician

supervision, meaning that a physician must be in the building whenever a

Medicare client is seen for therapy. According to her, this was a Medicare

ruling in 2001. (In fact, she is following a discussion that indicates the

ruling was misinterpreted all this time and really means that the physician

must be in the room!) This apparently doesn't apply to non-hospital- based

outpatient centers, and any on-site centers are assumed to have a physician

in the Emergency Department. I have worked in both the private practice and

hospital arenas, including hospital-based, off-site outpatient therapy

centers and I've never heard of this ruling before. In fact, many centers

I'm aware of don't have a physician for miles. My questions to the group:

- Have you ever heard of this ruling or discussion before?

- Does your hospital have off-site outpatient therapy and if so, how do you

meet this requirement while still providing access for extended hours

(evenings, weekends, etc)?

- Is APTA/AOTA involved in this discussion? I haven't heard anything.

Any feedback is appreciated! I do have copies (pdf files) of letters

discussing the ruling, etc if you're interested.

Christen, PT

Kchristen1fhn (DOT) org

Director of Rehabilitation Services

FHN

Freeport, IL