CMS has recently released a fact sheet that outlines the steps that PTs
should take to avoid an audit. Comprehensive Error Rate Testing (CERT) found
that the error rate for PT is high. The primary cause for a PT audit is
insufficient documentation. The specific
issues that contributed to this finding included:
1. Missing or incomplete plans of care.
2. Missing physician signatures and dates for plan of care and
certifications.
3. Missing total treatment times.
4. Missing certification and re-certification.
6. Billing for services under one PT provider number instead of
billing under each PT.
To minimize audit risks, additional suggestions include:
1. Billable services must be provided by a PT ot PTA.
2. Proper supervision of PTAs. For Medicare, private practice settings
require direct on premise supervision.
(Always follow State laws as well).
3. If 1 on 1 codes are employed, the patient contact must be
direct.
4. Co-treatment is not billable in outpatient settings.
5. Comply with the 8 Minute Rule (8-22 minutes = 1 unit, 23-37 minutes
= 2 units, etc.).
6. Treatment is Medically Necessary.
7. Billed services are not up-coded or unbundled.
8. Do not bill for student services.
9. Notes and signatures are legible.
10. Only written or electronic signatures (no stamps).
11. Every PT is enrolled in Medicare and has a provider number.
These topics have been covered in previous posts on this website,
especially from the RAC perspective. The most succeptible area remains establishing mecially necessary treatment. However, though RACs can be more
aggressive, there are other auditing entities for which concern is
warranted. The entities include:
1. CERT- random post payment audits.
2. MASc- Targeted pre and post payment audits.
3. ZPIC/PSC-targeted post payment audits.
4. OIG- targeted post payment audits.
If you need a quick refresher of the steps that will remove you from harm's way please
review the posts on this website. If I can be of service, please call.
Regards,