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