Medicare Part B Certifications and Recertifications

October 9, 2017
Rick Gawenda

I receive many questions regarding certifications and recertifications for Part B therapy services. Some of the most common questions I receive are the following:

  • How long is a certification and recertification valid for under Medicare Part B outpatient therapy services?
  • How soon must a plan of care be signed by a physician or NPP to be considered timely under Medicare Part B rules and regulations?
  • Who can sign a plan of care certifying and recertifying for outpatient therapy services under the Medicare program?
  • What is delayed certification and recertification?
  • What are some possible justifications to support delayed certification or recertification?
  • If I only do an evaluation on a Medicare beneficiary under Part B and discharge them as they do not required continued therapy, must I have the plan of care signed and dated by the physician/non-physician practitioner?
  • If I evaluate and treat a Medicare beneficiary in the emergency department or while under observation status and they do not get admitted to the hospital (i.e. they get discharged home), must I have the plan of care signed and dated by the physician?

In this article, I will answer all of the above questions and provide the reference for my answers. Lets begin!

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    1. This article is not specific to any one discipline. The certification and recertification process is the same for all 3 disciplines.

  1. Mr. Gawenda;
    I read your article and also all the other questions and responses. Upon review of our Conditions of Participation (hospital owned Outpatient rehab facility) I am still in need of clarification. Our intial evaluations, progress reports, re-certs and discharge summaries are dated and signed, but the typed reports which are faxed to the referring physician do not contain the time that they were performed. However, our accompanying daily note for the chart lists the total timed minutes and total treatment time. Is this adequate and in compliance? Thank you.

    1. Due to liability reasons, this is not a question I can answer in this forum. I would recommend you consult with your Compliance Officer.

  2. If a physician signs a certification and then faxes that to our office, is that acceptable?

  3. Do you know what the time frame requirement for progress notes in Michigan is? I can’t find anything in the state practice act that spells that out.

    1. Some state practice acts may not dictate how often a Progress Report has to be completed. I would recommend you contact the Michigan Physical Therapy Association and they would be able to assist you.

  4. what if a physician signature is provided on a prescription by his or her nurse? We often get orders with the physicians name/followed by the nurses initials. We have been sending back for physician to sign but this of course takes effort! Is it necessary?! I cannot see that this is addressed to this specificity in my state practice act.

    1. The Medicare program requires a signed and dated plan of care in order for you to be paid for therapy services. The physician order would not suffice.

  5. How often (even if the plan of care/initial Rx is written for longer) do we need to provide communication to the provider about a Medicare patient in outpt PT. I have been told we need to provide an “update” every 28 days, others say 30 but, I cannot actually find documentation to support either of these. So, If I write a plan of Care for 2x/week for 6 weeks, can I wait until the end of the 6th week to provide “communication” (and an additional POC, if necessary) OR do I have to provide “updates” to the provider throughout the six week duration (at the 28 or 30 day mark?)

    1. CMS has no requirement of how often you have to provide updated progress to the patient’s physician receiving outpatient therapy services. As you stated, you do have to have a certified plan of care that covers the visits and duration of therapy you are providing.

  6. Rick –
    Does having current/signed plans of care negate the need to constantly obtain further prescriptions to cover the same date ranges covered in the plan of care?

    1. The Medicare program does not require an order for outpatient therapy. What is required is a signed and dated plan of care.

  7. Rick,
    If a patient is evaluated and seen for 8 visits within the 30 days and discharged, does the discharge note need the ordering physician’s signature in order to close and discharge the chart fully? This patient is covered by the MD’s signature on the original Plan of Care. Thanks!

    1. The Medicare program and commercial insurance carriers do not require the discharge report be signed by the physician.

  8. Rick,
    We are looking for information on how to count visits after a reevaluation (recertification of a POC) for determining when the next progress note is due. From your previous webinars, I believe the visit on the day of the evaluation counts as visit #1 (similar to an initial eval). Where can I find this written information?

  9. If a patient’s discharge visit occurs after the certification period ends, even 1 day after, must a new POC be written and signed by the referring physician? If so, could the discharge note concurrently be a POC if it contains all the required criteria?

    1. You would need to have a certification that contains all the required elements to cover that one visit.