Let's Help Each Other

Physical therapy is changing rapidly. As a PT with more than thirty years of experience, the changes observed in the last ten years triple those of the first twenty years. The pace of change is not slowing down. The Medigraph Blog will serve as a forum that will enable us to exchange ideas and assist each other. This blog will be used to share billing, documentation, and any other ideas to improve any aspects of our profession. If we share what we have learned, we can develop a resource that enables our collective understanding to advance our careers.

As profit margins grow smaller and expenses grow larger, we need to assist each other to survive and prosper. If we share our experiences we can help each other to grow professionally, administratively, and financially. Our professional lives, our livelihood, and our personal lives are intertwined. Our resources individually are limited. Together we can accomplish more than we can individually. Let's help each other


Tom Kane, PT
MediGraph Software

Unannounced Medicare On Site Visits Effective March 25, 2011
4/1/2011 3:24:00 PM

CMS (The Centers for Medicare and Medicaid Services released information on  new provider enrollment screening regulations.   In these new regulations physical therapists in private practice are not required to undergo site visits before they enroll in  Medicare.  However, PTs are subject to unannounced  on-site visits after they are enrolled.  Theses new measures are intended to curb fraud and abuse.  Physical therapy practices are characterized as moderate risks for fraud (the other categories are Limited and High Risk).  However, physical therapist that bill for DME will be placed in the High Risk category, and will be subject to the on site unnanounced visit standards in this category.

An unannounced site visit will include the date and time of the visit,  observations made at the facility,  and photographs will be taken of the therapists.  Obviously, unannounced visit contractors must enter the office or facility.  If any of the basic elements are not met, the provider's Medicare billing privileges can be revoked.  The changes can be viewed at: http://www.cms.gov/transmittals/downloads/R371PI.pdf.

The long term effect of these Draconian government actions are undetermined.  As overreaching these rules may be, my greater concerns are those that involve human behavior.  Medicare and RAC contractors are subject to the human frailties that unbridled authority can have on behavior, where ordinary people can become monsters because of they are placed in an authoritative position.  Bullying by government officials is not an unusual occurrence, and at the first sign of weakness, many government enforcers will jump at the opportunity to wield their prowess.   Is there fraud in PT?  Of course there is.  Is it rampant?  I do not believe fraud is rampant within our ranks.  I do believe that the incidents of fraud that are severe become sensationalized and ridiculous regulations to address the few inconvenience the rest of us. 

Personal feelings aside, the best defense in these situations are a good offense.  Are you using MediGraph in a way that helps to serve you in these uncertain times?   Are you employing the objective outcome based documentation that defeats audits and prevents them from occurring?  I have sent emails and provided many posts on the importance of objective documentation and outcomes.  Both impairment measurement and functional outcomes tests (including OPTIMAL) are in MediGraph.  Please use them.  Also, prior to this recent CMS ruling, we at MediGraph were working on an electronic Medicare Manual.  We should have this product completed in a few weeks.  When the unannounced on site Medicare examiner visits your facility and asks for your Medicare Manual, you will be able to produce an up to date document at the click of a button.  

Our desire and actions that demonstrate our clinical competence and concern for our patients is not a defense against RACs and unannounced agency examiners.   The auditors’ job has nothing to do with quality care.  Use MediGraph to beat them at their own game while simultaneously elevating your clinical intervention.

Best regards,

Tom Kane, PT
MediGraph Software