Can I Double Book Medicare Patients?

February 17, 2020
Rick Gawenda

Previously, I wrote an article explaining how much time of a time-based CPT code must be provided in order to bill that CPT code to an insurance carrier as well as explaining the difference between Medicare’s “8-minute rule” and the American Medical Association (AMA) definition of substantial when billing a time-based CPT code. This article then led people to ask me if I can double book and/or overlap Medicare patients receiving outpatient therapy services. I’m going to answer this question once and for all and the answer will not only apply to outpatient therapy services paid under Medicare Part B benefits, but will also apply to commercial insurance carriers, workers compensation carriers and any other third party you are submitting outpatient claims to for reimbursement of outpatient therapy services.

What we need to remember is no insurance carrier cares or dictates how you schedule their patient’s for outpatient therapy services and this also includes the Medicare program. What insurance carriers, including the Medicare program, do care about is that their patient’s receive quality and medically necessary therapy services and that those services are billed correctly based on the description of each CPT code and the amount of time spent with the patient.

The biggest mistake I find that providers make is that they do not realize the description of the CPT codes that state “requires direct (one-on-one) patient contact” applies to all patient’s and all insurance carriers, not just the Medicare program. So if a CPT code states “requires direct (one-on-one) patient contact”, the therapist or assistant must be one-on-one with that patient in order to bill that CPT code to the insurance carrier.

So lets answer the question “Can I double book Medicare patient’s”? The answer is

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I hope you enjoyed this article and that we can finally put to rest the myth you can’t double book Medicare patient’s. Thank you for being a Gold Member!

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  1. Hi Rick,

    Thank you for continuing to provide valuable insight on billing and compliance issues! Do you have a reference for the AMA’s substantial time rule?


  2. These scenarios are extremely helpfu!!! A challenge that I find the MOST being a traveler working OP private practice and hospital settings is the stacking of commercial insurance with Medicare patients and the utilizing of PT techs with billing expectations and productivity in place. Learning how to stack and being able to bill legally/ethically and fair would be great! Obviously only a PT can bill for the time with a MC patient. The question is more – what about the non MC patient.

  3. Thank you Rick for that insightful article. It does put a lot into perspective for us as clinicians. It is a great article to create teaching moments for our therapists.