Can a Physician Order Serve as the Initial Certification?

September 1, 2025
 / 
Rick Gawenda
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There is confusion as to whether or not a physician order can serve as the initial plan of care for an original Medicare beneficiary receiving outpatient therapy. In this article, I will answer the following questions:

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  1. Further question – if the physician order does not specify a frequency and duration, what could be assumed as the certification period based on the order? Would it be the period of certification that the therapist writes into the POC?

    For instance, if a therapist writes their initial POC for 3x/week x 8 weeks – and the physician order does not specify frequency and duration – would CMS still consider this initial 8 week period of therapy certified by the physician based on the order?

  2. If the order is for 2xs a week 6 weeks and the therapist sets the plan of care for 3 Xs a week for 8 weeks Does the therapists plan of care need signed?

  3. I have read your facts order standing for the certification. But I was wondering If the order specifies frequency and duration do we have to use that recommended Frequency and duration or does our plan of care over ride the order?
    Connie