A frequent trigger for RAC audits are time code violations, especially
un-timed codes. CMS documentation requirements call for a daily therapy
note to include the recording of minutes in timed codes as well as total minutes
of therapy. Unfortunately, many private insurance providers are beginning
to employ the same standards. To avoid triggering an audit your billing
minutes and your documentation minutes must coincide, which will prevent
RAC computer data mining triggers. When performing your documentation, use
the time recorder “Time in Time Out” utility in
MediGraph to document and
collaborate your intervention and charges. The following information is an
example of how to coordinate your clinical and administrative efforts to
maximize revenue while simultaneously providing quality treatment.
Counting Minutes for Timed Codes in 15 Minute Units and the Eight Minute
RuleTimed codes are subject to the Medicare "Eight-minute rule," and the total
number of billed units is limited by the total minutes in timed codes.
These confusing standards often trigger RAC audits because of conflicts between
documentation and billing.The eight-minute rule applies to any timed CPT code,
which is measured as a 15 minute unit. Therapists can bill a
single 15-minute unit for treatment greater than or equal to 8 minutes through
and including 22 minutes. If the duration of a single modality or procedure in a
day is greater than or equal to 23 minutes through and including 37 minutes,
then 2 units should be billed. Time intervals for 1 through 8 units are as
follows:
1 unit: ≥ 8 minutes through 22 minutes
2 units: ≥ 23 minutes through 37 minutes
3 units: ≥ 38 minutes through 52 minutes
4 units: ≥ 53 minutes through 67 minutes
5 units: ≥ 68 minutes through 82 minutes
6 units: ≥ 83 minutes through 97 minutes
7 units: ≥ 98 minutes through 112 minutes
8 units:≥ 113 minutes through 127 minutes
An example of timed code confusion is billing for ultrasound.
If an ultrasound procedure is less than eight minutes, it is not billed
directly. Instead, because those minutes are rolled into the total minutes
in timed codes, the result is an additional unit of another code being billed.
It may be simpler to bill for 8 minutes of ultrasound, which can easily be
accomplished by providing 5 minutes of continuous ultrasound to elevate tissue
temperature, followed by three minutes of pulsed ultrasound to gain the benefits
of the mechanical effects of ultrasound. CMS provides
guidance on the "eight-minute rule" in Chapter 5 of the Medicare Claims
Processing Manual. http://www.cms.gov/manuals/downloads/clm104c05.pdf,
pg. 24.
Un-timed Codes Un-timed codes are a favorite target of RACs and are responsible
for a large number of audits. It is important to understand that un-timed
codes can only be billed for one (1) unit of service regardless of the actual
time spent on a therapy encounter. For example, a therapy evaluation that takes
15, 30, or 60 minutes may be billed for one unit. There is no prohibition
(CMS Transmittal 1019, which since has been incorporated into the Medicare
Claims Processing Manual) against billing two separate and distinct un-timed
codes; for example a physical therapy evaluation on the same day as a
speech-language pathology evaluation. For more info on untimed codes see
Page 13 at:
http://www.cms.gov/MLNProducts/downloads/MedQtrlyComp_Newsletter_ICN903696.pdf.
Regards,
Tom Kane, PT
MediGraph Software