Physicians Certifying an Outpatient Therapy Plan of Care

August 1, 2022
 / 
Rick Gawenda
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In this article, I will answer the following questions regarding physicians and nonphysician practitioners certifying and recertifying an outpatient therapy plan of care:

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  1. Just to clarify: “If you bill any treatment codes on the same date of service as the evaluation, you would also need to have your plan of care signed and dated by the physician/non-physician practitioner.”

    Does this mean that if you get an order for ‘Eval and Treat’ and it is a single one-and-done visit, the plan of care must be signed? Or does the quoted text only refer to situations where you do not have an order?

    Thank you!

    1. “If you bill any treatment codes on the same date of service as the evaluation, you would also need to have your plan of care signed and dated by the physician/non-physician practitioner.” – Yes!

  2. Do you have any references for the necessity of obtaining a certification for treatment when it is performed on the evaluation date (in the case of a 1x visit)?

    1. If you bill treatment on the day of an evaluation and then DC the patient, the Medicare Part B certification requirements must be followed.

  3. Does the certifying physician/NPP have to practice/be licensed in the same State as the patient lives and receives Part B services?

    1. If required, the physician would need to be able to see the Medicare beneficiary, either in-person or via telehealth, so in my opinion, would need to be licensed in the state the patient is having therapy in.