Re: Hosp-based Off-Site Outpatient Rehab Supervision

[Guest guest]

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

Meryl:

Thank you so much for your response.

I read responses like that rather frequently, when the topic compares private

practice with other models.

Perhaps, you misunderstood the position of my argument.

Off course we are all one profession.

And no, most of us in private practice are just breaking even these days.

And no, if in negotiating with insurances you are better leveraged as being part

of the hospital, and you are not subject to the same [Medicare] cap the solo

practitioner is, and the remaining various costs of being in business are better

leveraged by the whole institution (I.e.: buying group health insurance for your

employees and many other leveraging opportunities), unless Math has changed

since I took classes, or logic for that matter, at the end of the day, our

obstacles and opportunities are quite different and not leveled at all. Indeed,

many times the PP will work with much less overhead. But the reasons why

overhead could not be lowered for OP PT in the hospital are very strange to me

and a topic for a different conversation (perhaps from the fact that the PT is

not the one writing the check and the CFO doesn't know enough about PT?) All the

other factors could be thrown in but just to create more confusion to such a

multifaceted situation (I.e.: hospital based being a more visible " presence " in

communities vs. PT in PP being a more " personalized " situation etc etc), but

none of it matters to my position, as you'll see situations across the whole

spectrum depending on where you are looking. Some hospitals are struggling.

Some private practices are closing. Some hospitals are blooming (OP PT). Some

PTs in PP are paying the bills. (And please, must ethics be always the reason

for the bloom or doom of PTs? Are we such a horrible group that gone un-policed

will always rape and murder?) But lets not complicate the issue by mixing

apples to bananas...

MY POINT BEING THAT the reason " apples " are paid in different rates, with

different caps, different regulations (most of all), is that rather than being

proposed and fought for us as a cohered professional group, the same things

(rates, caps, regulations) have been slipped in, proposed, passed, negotiated

and " politicated " by whomever has been wanting to profit (yes, profit! -

directly or indirectly (like the hospital that must have PT or it will lose the

edge against the " hospital across the bridge " ) from the commodity of physical

therapy.

Sincerely;

Armin Loges, PT

Tampa, FL

From: Freeman, Meryl

Sent: Tuesday, November 17, 2009 9:45 AM

To: PTManager

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

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

Meryl:

Thank you so much for your response.

I read responses like that rather frequently, when the topic compares private

practice with other models.

Perhaps, you misunderstood the position of my argument.

Off course we are all one profession.

And no, most of us in private practice are just breaking even these days.

And no, if in negotiating with insurances you are better leveraged as being part

of the hospital, and you are not subject to the same [Medicare] cap the solo

practitioner is, and the remaining various costs of being in business are better

leveraged by the whole institution (I.e.: buying group health insurance for your

employees and many other leveraging opportunities), unless Math has changed

since I took classes, or logic for that matter, at the end of the day, our

obstacles and opportunities are quite different and not leveled at all. Indeed,

many times the PP will work with much less overhead. But the reasons why

overhead could not be lowered for OP PT in the hospital are very strange to me

and a topic for a different conversation (perhaps from the fact that the PT is

not the one writing the check and the CFO doesn't know enough about PT?) All the

other factors could be thrown in but just to create more confusion to such a

multifaceted situation (I.e.: hospital based being a more visible " presence " in

communities vs. PT in PP being a more " personalized " situation etc etc), but

none of it matters to my position, as you'll see situations across the whole

spectrum depending on where you are looking. Some hospitals are struggling.

Some private practices are closing. Some hospitals are blooming (OP PT). Some

PTs in PP are paying the bills. (And please, must ethics be always the reason

for the bloom or doom of PTs? Are we such a horrible group that gone un-policed

will always rape and murder?) But lets not complicate the issue by mixing

apples to bananas...

MY POINT BEING THAT the reason " apples " are paid in different rates, with

different caps, different regulations (most of all), is that rather than being

proposed and fought for us as a cohered professional group, the same things

(rates, caps, regulations) have been slipped in, proposed, passed, negotiated

and " politicated " by whomever has been wanting to profit (yes, profit! -

directly or indirectly (like the hospital that must have PT or it will lose the

edge against the " hospital across the bridge " ) from the commodity of physical

therapy.

Sincerely;

Armin Loges, PT

Tampa, FL

From: Freeman, Meryl

Sent: Tuesday, November 17, 2009 9:45 AM

To: PTManager

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

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

Meryl:

Thank you so much for your response.

I read responses like that rather frequently, when the topic compares private

practice with other models.

Perhaps, you misunderstood the position of my argument.

Off course we are all one profession.

And no, most of us in private practice are just breaking even these days.

And no, if in negotiating with insurances you are better leveraged as being part

of the hospital, and you are not subject to the same [Medicare] cap the solo

practitioner is, and the remaining various costs of being in business are better

leveraged by the whole institution (I.e.: buying group health insurance for your

employees and many other leveraging opportunities), unless Math has changed

since I took classes, or logic for that matter, at the end of the day, our

obstacles and opportunities are quite different and not leveled at all. Indeed,

many times the PP will work with much less overhead. But the reasons why

overhead could not be lowered for OP PT in the hospital are very strange to me

and a topic for a different conversation (perhaps from the fact that the PT is

not the one writing the check and the CFO doesn't know enough about PT?) All the

other factors could be thrown in but just to create more confusion to such a

multifaceted situation (I.e.: hospital based being a more visible " presence " in

communities vs. PT in PP being a more " personalized " situation etc etc), but

none of it matters to my position, as you'll see situations across the whole

spectrum depending on where you are looking. Some hospitals are struggling.

Some private practices are closing. Some hospitals are blooming (OP PT). Some

PTs in PP are paying the bills. (And please, must ethics be always the reason

for the bloom or doom of PTs? Are we such a horrible group that gone un-policed

will always rape and murder?) But lets not complicate the issue by mixing

apples to bananas...

MY POINT BEING THAT the reason " apples " are paid in different rates, with

different caps, different regulations (most of all), is that rather than being

proposed and fought for us as a cohered professional group, the same things

(rates, caps, regulations) have been slipped in, proposed, passed, negotiated

and " politicated " by whomever has been wanting to profit (yes, profit! -

directly or indirectly (like the hospital that must have PT or it will lose the

edge against the " hospital across the bridge " ) from the commodity of physical

therapy.

Sincerely;

Armin Loges, PT

Tampa, FL

From: Freeman, Meryl

Sent: Tuesday, November 17, 2009 9:45 AM

To: PTManager

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

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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 think you have to go back and look at history to understand the caps.

Physical Therapy started as a hospital based program. Patients came to the

hospital and if needed spent weeks there for therapy. Medicare noticed that

Private Practice existed but limited their yearly charges to $500.thus

Medicare was not even considered for PP revenue. (I was part of a group of

aggressive clinical therapists in Little Rock in the late 70's that

considered starting private practice. We eventually dropped the idea since

there was already a PP in Little Rock and we did not think the area could

support 2 of those.)

PT's fought to expand their coverage and public acceptance. Clinton changed

everything in billing with healthcare reform. The cap was leveled for SNF

and Private Practice and billing standardized. PP saw a boost in their

rates and SNF saw a decline. For some reason the hospitals were ignored but

they were already undergoing heavy change with a PPS system for their

primary revenue. Hospitals moved to OP to balance their revenue and

overhead.

The system like most of our regs is changed in piece meal. We have never

set a comprehensive Medicare and Caid plan and I am sure we would not like

one.

Steve Passmore PT, MS

President Healthy Recruiting Tools

www.HealthyRecruiting.com

spass@...

Phone:

Fax:

" What We Did For You Yesterday is History...What Can We Do For You Today "

From: PTManager [mailto:PTManager ] On Behalf

Of Armin Loges, PT

Sent: Tuesday, November 17, 2009 7:44 AM

To: PTManager

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

:

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@... <mailto:hilljeremy%40bellsouth.net>

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

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

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 think you have to go back and look at history to understand the caps.

Physical Therapy started as a hospital based program. Patients came to the

hospital and if needed spent weeks there for therapy. Medicare noticed that

Private Practice existed but limited their yearly charges to $500.thus

Medicare was not even considered for PP revenue. (I was part of a group of

aggressive clinical therapists in Little Rock in the late 70's that

considered starting private practice. We eventually dropped the idea since

there was already a PP in Little Rock and we did not think the area could

support 2 of those.)

PT's fought to expand their coverage and public acceptance. Clinton changed

everything in billing with healthcare reform. The cap was leveled for SNF

and Private Practice and billing standardized. PP saw a boost in their

rates and SNF saw a decline. For some reason the hospitals were ignored but

they were already undergoing heavy change with a PPS system for their

primary revenue. Hospitals moved to OP to balance their revenue and

overhead.

The system like most of our regs is changed in piece meal. We have never

set a comprehensive Medicare and Caid plan and I am sure we would not like

one.

Steve Passmore PT, MS

President Healthy Recruiting Tools

www.HealthyRecruiting.com

spass@...

Phone:

Fax:

" What We Did For You Yesterday is History...What Can We Do For You Today "

From: PTManager [mailto:PTManager ] On Behalf

Of Armin Loges, PT

Sent: Tuesday, November 17, 2009 7:44 AM

To: PTManager

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

:

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@... <mailto:hilljeremy%40bellsouth.net>

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

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

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 think you have to go back and look at history to understand the caps.

Physical Therapy started as a hospital based program. Patients came to the

hospital and if needed spent weeks there for therapy. Medicare noticed that

Private Practice existed but limited their yearly charges to $500.thus

Medicare was not even considered for PP revenue. (I was part of a group of

aggressive clinical therapists in Little Rock in the late 70's that

considered starting private practice. We eventually dropped the idea since

there was already a PP in Little Rock and we did not think the area could

support 2 of those.)

PT's fought to expand their coverage and public acceptance. Clinton changed

everything in billing with healthcare reform. The cap was leveled for SNF

and Private Practice and billing standardized. PP saw a boost in their

rates and SNF saw a decline. For some reason the hospitals were ignored but

they were already undergoing heavy change with a PPS system for their

primary revenue. Hospitals moved to OP to balance their revenue and

overhead.

The system like most of our regs is changed in piece meal. We have never

set a comprehensive Medicare and Caid plan and I am sure we would not like

one.

Steve Passmore PT, MS

President Healthy Recruiting Tools

www.HealthyRecruiting.com

spass@...

Phone:

Fax:

" What We Did For You Yesterday is History...What Can We Do For You Today "

From: PTManager [mailto:PTManager ] On Behalf

Of Armin Loges, PT

Sent: Tuesday, November 17, 2009 7:44 AM

To: PTManager

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

:

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@... <mailto:hilljeremy%40bellsouth.net>

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

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

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]

What is missing in the analysis of obstacles and opportunities is the context of

uncountable and dense regulations surrounding the delivery of medical care.

Hospitals and SNFs are certainly regulated far more than private practices, but

ALL providers are pushed this way and that by forces far distant from the

patient-provider relationship and the free market.

It is truly all but impossible to consider the myriad overlapping rules that

affect practice. Third-party reimbursement rules (especially from

government-provided and government-modulated programs) are particularly dense

and controlling, but there are many, many other unnatural forces at work as

well, both direct and indirect.

We are, for example, a rural hospital system dealing continually with rules

driven by government's notion of which regions have greater or lesser need for

physicians. Such classifications affect hiring, reimbursement, capital and

operational decisions, and of course referral patterns. This is just one of a

zillion interrelated forces.

Here's another example that I have pointed up before: We are a not-for-profit

community-owned hospital system. The state establishes a " partnership " with us

to serve our population, basically mandating that we see everyone without regard

to ability to pay, and in return receive state-mediated reimbursement. That

reimbursement is of course a complicated and twisted system of fees, cost

reports, grants, programs, and God only knows what else. In the end we almost

always find ourselves on the brink of financial disaster. Now in Rehab Services,

if we could, say, do as our local private practice competitors do and refuse to

accept Medical Assistance patients, we could effectively wipe out our financial

problems. Of course that would leave a large chunk of our population without

services, so we wouldn't do it even if we were allowed to. So does that little

problem make up for the cap?

The answer is: Who knows? Discussions of this or that group's relative

advantages and disadvantages in this crazy system are simply not productive. And

given the massive inertia of this bowl of regulatory spaghetti it's unlikely

that there can ever be a sane discussion of all the salient factors.

Complexity is indeed a scoundrel's refuge.

Dave Milano, PT

Rehabilitation Director

Laurel Health System

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Armin Loges, PT

Sent: Tuesday, November 17, 2009 10:49 AM

To: PTManager

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

Meryl:

Thank you so much for your response.

I read responses like that rather frequently, when the topic compares private

practice with other models.

Perhaps, you misunderstood the position of my argument.

Off course we are all one profession.

And no, most of us in private practice are just breaking even these days.

And no, if in negotiating with insurances you are better leveraged as being part

of the hospital, and you are not subject to the same [Medicare] cap the solo

practitioner is, and the remaining various costs of being in business are better

leveraged by the whole institution (I.e.: buying group health insurance for your

employees and many other leveraging opportunities), unless Math has changed

since I took classes, or logic for that matter, at the end of the day, our

obstacles and opportunities are quite different and not leveled at all. Indeed,

many times the PP will work with much less overhead. But the reasons why

overhead could not be lowered for OP PT in the hospital are very strange to me

and a topic for a different conversation (perhaps from the fact that the PT is

not the one writing the check and the CFO doesn't know enough about PT?) All the

other factors could be thrown in but just to create more confusion to such a

multifaceted situation (I.e.: hospital based being a more visible " presence " in

communities vs. PT in PP being a more " personalized " situation etc etc), but

none of it matters to my position, as you'll see situations across the whole

spectrum depending on where you are looking. Some hospitals are struggling. Some

private practices are closing. Some hospitals are blooming (OP PT). Some PTs in

PP are paying the bills. (And please, must ethics be always the reason for the

bloom or doom of PTs? Are we such a horrible group that gone un-policed will

always rape and murder?) But lets not complicate the issue by mixing apples to

bananas...

MY POINT BEING THAT the reason " apples " are paid in different rates, with

different caps, different regulations (most of all), is that rather than being

proposed and fought for us as a cohered professional group, the same things

(rates, caps, regulations) have been slipped in, proposed, passed, negotiated

and " politicated " by whomever has been wanting to profit (yes, profit! -

directly or indirectly (like the hospital that must have PT or it will lose the

edge against the " hospital across the bridge " ) from the commodity of physical

therapy.

Sincerely;

Armin Loges, PT

Tampa, FL

From: Freeman, Meryl

Sent: Tuesday, November 17, 2009 9:45 AM

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

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

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

What is missing in the analysis of obstacles and opportunities is the context of

uncountable and dense regulations surrounding the delivery of medical care.

Hospitals and SNFs are certainly regulated far more than private practices, but

ALL providers are pushed this way and that by forces far distant from the

patient-provider relationship and the free market.

It is truly all but impossible to consider the myriad overlapping rules that

affect practice. Third-party reimbursement rules (especially from

government-provided and government-modulated programs) are particularly dense

and controlling, but there are many, many other unnatural forces at work as

well, both direct and indirect.

We are, for example, a rural hospital system dealing continually with rules

driven by government's notion of which regions have greater or lesser need for

physicians. Such classifications affect hiring, reimbursement, capital and

operational decisions, and of course referral patterns. This is just one of a

zillion interrelated forces.

Here's another example that I have pointed up before: We are a not-for-profit

community-owned hospital system. The state establishes a " partnership " with us

to serve our population, basically mandating that we see everyone without regard

to ability to pay, and in return receive state-mediated reimbursement. That

reimbursement is of course a complicated and twisted system of fees, cost

reports, grants, programs, and God only knows what else. In the end we almost

always find ourselves on the brink of financial disaster. Now in Rehab Services,

if we could, say, do as our local private practice competitors do and refuse to

accept Medical Assistance patients, we could effectively wipe out our financial

problems. Of course that would leave a large chunk of our population without

services, so we wouldn't do it even if we were allowed to. So does that little

problem make up for the cap?

The answer is: Who knows? Discussions of this or that group's relative

advantages and disadvantages in this crazy system are simply not productive. And

given the massive inertia of this bowl of regulatory spaghetti it's unlikely

that there can ever be a sane discussion of all the salient factors.

Complexity is indeed a scoundrel's refuge.

Dave Milano, PT

Rehabilitation Director

Laurel Health System

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Armin Loges, PT

Sent: Tuesday, November 17, 2009 10:49 AM

To: PTManager

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

Meryl:

Thank you so much for your response.

I read responses like that rather frequently, when the topic compares private

practice with other models.

Perhaps, you misunderstood the position of my argument.

Off course we are all one profession.

And no, most of us in private practice are just breaking even these days.

And no, if in negotiating with insurances you are better leveraged as being part

of the hospital, and you are not subject to the same [Medicare] cap the solo

practitioner is, and the remaining various costs of being in business are better

leveraged by the whole institution (I.e.: buying group health insurance for your

employees and many other leveraging opportunities), unless Math has changed

since I took classes, or logic for that matter, at the end of the day, our

obstacles and opportunities are quite different and not leveled at all. Indeed,

many times the PP will work with much less overhead. But the reasons why

overhead could not be lowered for OP PT in the hospital are very strange to me

and a topic for a different conversation (perhaps from the fact that the PT is

not the one writing the check and the CFO doesn't know enough about PT?) All the

other factors could be thrown in but just to create more confusion to such a

multifaceted situation (I.e.: hospital based being a more visible " presence " in

communities vs. PT in PP being a more " personalized " situation etc etc), but

none of it matters to my position, as you'll see situations across the whole

spectrum depending on where you are looking. Some hospitals are struggling. Some

private practices are closing. Some hospitals are blooming (OP PT). Some PTs in

PP are paying the bills. (And please, must ethics be always the reason for the

bloom or doom of PTs? Are we such a horrible group that gone un-policed will

always rape and murder?) But lets not complicate the issue by mixing apples to

bananas...

MY POINT BEING THAT the reason " apples " are paid in different rates, with

different caps, different regulations (most of all), is that rather than being

proposed and fought for us as a cohered professional group, the same things

(rates, caps, regulations) have been slipped in, proposed, passed, negotiated

and " politicated " by whomever has been wanting to profit (yes, profit! -

directly or indirectly (like the hospital that must have PT or it will lose the

edge against the " hospital across the bridge " ) from the commodity of physical

therapy.

Sincerely;

Armin Loges, PT

Tampa, FL

From: Freeman, Meryl

Sent: Tuesday, November 17, 2009 9:45 AM

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

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

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

What is missing in the analysis of obstacles and opportunities is the context of

uncountable and dense regulations surrounding the delivery of medical care.

Hospitals and SNFs are certainly regulated far more than private practices, but

ALL providers are pushed this way and that by forces far distant from the

patient-provider relationship and the free market.

It is truly all but impossible to consider the myriad overlapping rules that

affect practice. Third-party reimbursement rules (especially from

government-provided and government-modulated programs) are particularly dense

and controlling, but there are many, many other unnatural forces at work as

well, both direct and indirect.

We are, for example, a rural hospital system dealing continually with rules

driven by government's notion of which regions have greater or lesser need for

physicians. Such classifications affect hiring, reimbursement, capital and

operational decisions, and of course referral patterns. This is just one of a

zillion interrelated forces.

Here's another example that I have pointed up before: We are a not-for-profit

community-owned hospital system. The state establishes a " partnership " with us

to serve our population, basically mandating that we see everyone without regard

to ability to pay, and in return receive state-mediated reimbursement. That

reimbursement is of course a complicated and twisted system of fees, cost

reports, grants, programs, and God only knows what else. In the end we almost

always find ourselves on the brink of financial disaster. Now in Rehab Services,

if we could, say, do as our local private practice competitors do and refuse to

accept Medical Assistance patients, we could effectively wipe out our financial

problems. Of course that would leave a large chunk of our population without

services, so we wouldn't do it even if we were allowed to. So does that little

problem make up for the cap?

The answer is: Who knows? Discussions of this or that group's relative

advantages and disadvantages in this crazy system are simply not productive. And

given the massive inertia of this bowl of regulatory spaghetti it's unlikely

that there can ever be a sane discussion of all the salient factors.

Complexity is indeed a scoundrel's refuge.

Dave Milano, PT

Rehabilitation Director

Laurel Health System

________________________________

From: PTManager [mailto:PTManager ] On Behalf Of

Armin Loges, PT

Sent: Tuesday, November 17, 2009 10:49 AM

To: PTManager

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

Meryl:

Thank you so much for your response.

I read responses like that rather frequently, when the topic compares private

practice with other models.

Perhaps, you misunderstood the position of my argument.

Off course we are all one profession.

And no, most of us in private practice are just breaking even these days.

And no, if in negotiating with insurances you are better leveraged as being part

of the hospital, and you are not subject to the same [Medicare] cap the solo

practitioner is, and the remaining various costs of being in business are better

leveraged by the whole institution (I.e.: buying group health insurance for your

employees and many other leveraging opportunities), unless Math has changed

since I took classes, or logic for that matter, at the end of the day, our

obstacles and opportunities are quite different and not leveled at all. Indeed,

many times the PP will work with much less overhead. But the reasons why

overhead could not be lowered for OP PT in the hospital are very strange to me

and a topic for a different conversation (perhaps from the fact that the PT is

not the one writing the check and the CFO doesn't know enough about PT?) All the

other factors could be thrown in but just to create more confusion to such a

multifaceted situation (I.e.: hospital based being a more visible " presence " in

communities vs. PT in PP being a more " personalized " situation etc etc), but

none of it matters to my position, as you'll see situations across the whole

spectrum depending on where you are looking. Some hospitals are struggling. Some

private practices are closing. Some hospitals are blooming (OP PT). Some PTs in

PP are paying the bills. (And please, must ethics be always the reason for the

bloom or doom of PTs? Are we such a horrible group that gone un-policed will

always rape and murder?) But lets not complicate the issue by mixing apples to

bananas...

MY POINT BEING THAT the reason " apples " are paid in different rates, with

different caps, different regulations (most of all), is that rather than being

proposed and fought for us as a cohered professional group, the same things

(rates, caps, regulations) have been slipped in, proposed, passed, negotiated

and " politicated " by whomever has been wanting to profit (yes, profit! -

directly or indirectly (like the hospital that must have PT or it will lose the

edge against the " hospital across the bridge " ) from the commodity of physical

therapy.

Sincerely;

Armin Loges, PT

Tampa, FL

From: Freeman, Meryl

Sent: Tuesday, November 17, 2009 9:45 AM

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

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

Armin:

I work in a hospital outpatient setting and I can tell you with

certainty that the hospital does not make any money from our services.

Like all other outpatient settings who bill legally and ethically, we

are very lucky if we break even. We are not a profit center for the

hospital and are considered one of those necessary services that will

not get much attention or capital, but exists only to provide the

service. Our hospital does not employ physicians that refer to PT and we

are out there competing with private practices, corporates, and POPTS

for patients just like you are.

We are subject to the same expense/revenue issues you are. Salaries and

non-controllable expenses are going up, reimbursement is going down.

These are major issues that we all share. They are issues we all need to

address as a profession.

As for the non-cap with hospitals, my understanding was that CMS based

this on a utilization study that showed overall hospital-based

utilization of PT was less than that of the private sector. I could be

mistaken. I agree with you that private practice may be at a

disadvantage with negotiations for reimbursement, etc, but I can tell

you that as a profession, we are all struggling with the same issues.

I honestly don't know how anyone, private practice or otherwise, makes

any profit. Change of subject here, but is anyone out there doing more

than breaking even while practicing/billing in an ethical manner? If

so, I'd sure like to hear about your model.

Regards,

Meryl W. Freeman, MS PT

Manager, Outpatient Rehab

Raleigh, NC

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]

Armin,

I respectfully disagree - hospitals were not exempted from the PT caps based on

lobbying but by policy makers answering real concerns about restricted patient

access due to the caps.

CMS needed to find out the following (from OTAPS 2, March 21, 2008)...

http://www.cms.hhs.gov/TherapyServices/downloads/OTAPS_2_CY_2006_Outpatient_Ther\

apy_Cap_Report_PDF_Final.pdf

" Did the addition of the exceptions process to the therapy cap policy serve the

intended purpose of controlling costs while assuring that the beneficiaries that

needed therapy services received them?

(If) the exceptions process (is) eliminated what are the characteristics of

beneficiaries and providers that would most likely be impacted? "

CMS found that the caps, while an imperfect mechanism, did control costs while

APPARENTLY preserving access to PT services:

" The outpatient therapy caps, as implemented in CY 2006 with the exceptions

process, had little or no impact on beneficiary access to outpatient therapy

services as the number of beneficiaries receiving therapy services increased

3.5%... "

My concern is that the 3.5% growth is aggregate growth - the growth rate serves

as a proxy for access.

Did CMS determine the characteristics of beneficiaries impacted? No, they

determined that beneficiaries were NOT impacted.

If growth in costs rise commensurate with growth in numbers treated then CMS

assumes that everyone who NEEDS therapy is getting therapy.

We all know the reality - some clinics automatically discharge patients at

$1,840 - regardless of need or progress. This decision is based on perceived

audit risk.

BTW, I don't think PT is a big profit center for most hospitals anymore - PT has

a big footprint, therapists are expensive, and reimbursements are declining.

Lobbying is also expensive.

Better to invest your time in specialty outpatient surgery, bariatric surgery,

or some other high-margin venture.

Tim , PT

timrichpt@...

www.PhysicalTherapyDiagnosis.com

>

> 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]

Armin,

I respectfully disagree - hospitals were not exempted from the PT caps based on

lobbying but by policy makers answering real concerns about restricted patient

access due to the caps.

CMS needed to find out the following (from OTAPS 2, March 21, 2008)...

http://www.cms.hhs.gov/TherapyServices/downloads/OTAPS_2_CY_2006_Outpatient_Ther\

apy_Cap_Report_PDF_Final.pdf

" Did the addition of the exceptions process to the therapy cap policy serve the

intended purpose of controlling costs while assuring that the beneficiaries that

needed therapy services received them?

(If) the exceptions process (is) eliminated what are the characteristics of

beneficiaries and providers that would most likely be impacted? "

CMS found that the caps, while an imperfect mechanism, did control costs while

APPARENTLY preserving access to PT services:

" The outpatient therapy caps, as implemented in CY 2006 with the exceptions

process, had little or no impact on beneficiary access to outpatient therapy

services as the number of beneficiaries receiving therapy services increased

3.5%... "

My concern is that the 3.5% growth is aggregate growth - the growth rate serves

as a proxy for access.

Did CMS determine the characteristics of beneficiaries impacted? No, they

determined that beneficiaries were NOT impacted.

If growth in costs rise commensurate with growth in numbers treated then CMS

assumes that everyone who NEEDS therapy is getting therapy.

We all know the reality - some clinics automatically discharge patients at

$1,840 - regardless of need or progress. This decision is based on perceived

audit risk.

BTW, I don't think PT is a big profit center for most hospitals anymore - PT has

a big footprint, therapists are expensive, and reimbursements are declining.

Lobbying is also expensive.

Better to invest your time in specialty outpatient surgery, bariatric surgery,

or some other high-margin venture.

Tim , PT

timrichpt@...

www.PhysicalTherapyDiagnosis.com

>

> 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]

Armin,

I respectfully disagree - hospitals were not exempted from the PT caps based on

lobbying but by policy makers answering real concerns about restricted patient

access due to the caps.

CMS needed to find out the following (from OTAPS 2, March 21, 2008)...

http://www.cms.hhs.gov/TherapyServices/downloads/OTAPS_2_CY_2006_Outpatient_Ther\

apy_Cap_Report_PDF_Final.pdf

" Did the addition of the exceptions process to the therapy cap policy serve the

intended purpose of controlling costs while assuring that the beneficiaries that

needed therapy services received them?

(If) the exceptions process (is) eliminated what are the characteristics of

beneficiaries and providers that would most likely be impacted? "

CMS found that the caps, while an imperfect mechanism, did control costs while

APPARENTLY preserving access to PT services:

" The outpatient therapy caps, as implemented in CY 2006 with the exceptions

process, had little or no impact on beneficiary access to outpatient therapy

services as the number of beneficiaries receiving therapy services increased

3.5%... "

My concern is that the 3.5% growth is aggregate growth - the growth rate serves

as a proxy for access.

Did CMS determine the characteristics of beneficiaries impacted? No, they

determined that beneficiaries were NOT impacted.

If growth in costs rise commensurate with growth in numbers treated then CMS

assumes that everyone who NEEDS therapy is getting therapy.

We all know the reality - some clinics automatically discharge patients at

$1,840 - regardless of need or progress. This decision is based on perceived

audit risk.

BTW, I don't think PT is a big profit center for most hospitals anymore - PT has

a big footprint, therapists are expensive, and reimbursements are declining.

Lobbying is also expensive.

Better to invest your time in specialty outpatient surgery, bariatric surgery,

or some other high-margin venture.

Tim , PT

timrichpt@...

www.PhysicalTherapyDiagnosis.com

>

> 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]

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

[Guest guest]

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

[Guest guest]

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

[Guest guest]

Dave, well said. All areas of practice have major challenges and

regulations. There are some different challenges between private

practice and hospitals (JCAHO, state regulators, etc) and different

regions, but all are challenges just the same. We do need to focus on

issues that we have in common, and there are many of those to go around.

So back to my question- is anyone out there turning a profit in our

curent reality? If so, how?

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]

Dave, well said. All areas of practice have major challenges and

regulations. There are some different challenges between private

practice and hospitals (JCAHO, state regulators, etc) and different

regions, but all are challenges just the same. We do need to focus on

issues that we have in common, and there are many of those to go around.

So back to my question- is anyone out there turning a profit in our

curent reality? If so, how?

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]

Dave, well said. All areas of practice have major challenges and

regulations. There are some different challenges between private

practice and hospitals (JCAHO, state regulators, etc) and different

regions, but all are challenges just the same. We do need to focus on

issues that we have in common, and there are many of those to go around.

So back to my question- is anyone out there turning a profit in our

curent reality? If so, how?

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]

Tom:

I am not presuming to know. Much to the contrary...

So, what you are saying is that, after covering all the PT dept. expenses, pay

roll, rent, etc etc, there are still moneys from PT to support other

departments?

That, in PP world would be considered profit, would not? Which contradicts what

others have submitted about hospitals not profiting from PT.

In many areas, for private practice, Medicare is the better payer.

Sincerely:

Armin Loges, PT

Tampa, FL

From: Kaluzny, R.

Sent: Tuesday, November 17, 2009 2:20 PM

To: PTManager

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

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

[Guest guest]

Tom:

I am not presuming to know. Much to the contrary...

So, what you are saying is that, after covering all the PT dept. expenses, pay

roll, rent, etc etc, there are still moneys from PT to support other

departments?

That, in PP world would be considered profit, would not? Which contradicts what

others have submitted about hospitals not profiting from PT.

In many areas, for private practice, Medicare is the better payer.

Sincerely:

Armin Loges, PT

Tampa, FL

From: Kaluzny, R.

Sent: Tuesday, November 17, 2009 2:20 PM

To: PTManager

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

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

[Guest guest]

Tom:

I am not presuming to know. Much to the contrary...

So, what you are saying is that, after covering all the PT dept. expenses, pay

roll, rent, etc etc, there are still moneys from PT to support other

departments?

That, in PP world would be considered profit, would not? Which contradicts what

others have submitted about hospitals not profiting from PT.

In many areas, for private practice, Medicare is the better payer.

Sincerely:

Armin Loges, PT

Tampa, FL

From: Kaluzny, R.

Sent: Tuesday, November 17, 2009 2:20 PM

To: PTManager

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

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

[Guest guest]

Armin,

Actually I do know the difference between profit and loss. We

actually are about $600K short each year in the department, after

covering our department expenses. We can never meet the expenses and

margins that the hospital places on us to help support the entire

system. I know that Medicare is a better payor in some places, but we

are predominently Medicaid. I am trying to make the point that where

private practice owners feel that the playing field isn't level when

going against hospitals, I believe that it can go against us, especially

for the non profits. Private practice owners usually do not have a

whole hospital, let alone a system to support with what they make.

But....if this was a private practice, we would be making a profit.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

________________________________

From: PTManager [mailto:PTManager ] On

Behalf Of Armin Loges, PT

Sent: Tuesday, November 17, 2009 2:12 PM

To: PTManager

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

Supervision

Tom:

I am not presuming to know. Much to the contrary...

So, what you are saying is that, after covering all the PT dept.

expenses, pay roll, rent, etc etc, there are still moneys from PT to

support other departments?

That, in PP world would be considered profit, would not? Which

contradicts what others have submitted about hospitals not profiting

from PT.

In many areas, for private practice, Medicare is the better payer.

Sincerely:

Armin Loges, PT

Tampa, FL

From: Kaluzny, R.

Sent: Tuesday, November 17, 2009 2:20 PM

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

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

Supervision

Good Morning,

As a non profit, hospital based, rural outpatient PT service, I

think that there is another aspect to this line. While we do have to

compete with other private practices, eighty two percent of our

referrals are Medicare and Medicaid. Our local physicians refer mainly

those patient populations to us since we are non profit. We do not see

the higher end payors. This makes it very difficult for us to maintain

our margin. We are responsible for a nearly 7 figure margin to support

the other hospital based services (we are off site and have to pay our

own rent, cleaning, utilities, etc) and then are responsible for helping

to maintain the other services. We have been unable to meet our margin

responsibiltiy in the 7 years I have been manager. I was in private

practice for 10 years and have found it much harder to try and maintain

profitability in a hospital setting than I ever did in private practice.

Our productivity is at 107%, with overtime, so it is not a lack of

patients, just the patient mix since we are a non profit hospital.

Tom Kaluzny PT

Rehabilitation Services Manager

Providence Mount Carmel Hospital

982 E. Columbia

Colville, WA 99114

Work:

Fax:

email: thomas.kaluzny@...

<mailto:thomas.kaluzny%40providence.org>