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

CMS Audit Guidelines; Minimize Your Risk
2/4/2012 11:50:00 AM

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.

    5.  KX modifier.

    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.


Tom Kane, PT

800-804-6334  ext.210