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For
physicians confused about how to supervise therapists providing
services to their patients, hope is on the horizon.
You
won't receive a denial for therapy services merely because
the physician hasn't yet issued an order or referral for
therapy, the Centers for Medicare and Medicaid Services
says in Transmittal 3648, issued May 6. But Medicare will
deny the claim if the physician doesn't certify the plan
of care every 30 days, indicating that the patient was under
the care of the physician and needed the treatment in the
care plan.
The
carriers will be doing pre-payment and post-payment review
of therapy claims to make sure the physician certified the
plan of care for the first 30 days and each 30-day period
afterwards. But if the physician certification is delayed,
the carriers won't deny the claim unless it's clear from
the documentation that the services weren't medically necessary.
Also,
the physician isn't required to see the patient prior to
certifying the plan of care, but the physician still has
the authority to require a face-to-face visit before certification,
CMS explains.
The
therapist providing services must meet all the state and
federal requirements for a therapist, except for licensure,
CMS reiterates in the transmittal.
But
the transmittal doesn't reinstate CMS' canceled instructions
from last fall, which had instructed physicians to note
the names of the auxiliary personnel who were involved in
performing incident-to services on the claim form. That
requirement has been rescinded for good, CMS officials said
in the May 10 physician Open Door Forum.
More
information about the change is available here.
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