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Gawenda Seminars

Seminars and Consulting

Telehealth in 2021: What You Need to Know

Get the latest information on outpatient therapy delivered via telehealth by attending our “Telehealth in 2021: What You Need to Know” webinar on February 4, 2021. Click HERE to learn more and to register.

billing

Can Students Treat Medicare Patients and Bill For Those Services?

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I am often asked if the time a student treats a Medicare patient for physical, occupational and/or speech therapy services, is that time billable to the Medicare program? In this article, I will answer this question as it applies to inpatient acute care, inpatient rehabilitation facilities, skilled nursing facilities providing Part A therapy services and outpatient therapy settings.

Question
In the Inpatient Rehabilitation Facility (IRF) setting, do the minutes of therapy provided by the student therapist count towards the required 3-hours of therapy at least 5 days per week?

Answer

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Question
In the inpatient hospital acute care setting, can therapy students treat Medicare beneficiaries and have those services “billed” to the Medicare program?

Answer

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Question
In outpatient therapy, can a therapy student treat a Medicare Part B beneficiary and have those services billed to the Medicare program?

Answer

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Question
Under skilled nursing facility (SNF) Part A therapy services, do the minutes of therapy provided by the student count towards the billable time?

Answer

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I hope this article answered your questions regarding the billing of services provided by therapy students to the Medicare program. Thank you for being a Gold Member!

Effective Date of Enrollment and Retrospective Billing Date

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When a physical therapist, occupational therapist or speech-language pathologist in private practice enrolls in the Medicare program, how does the Centers for Medicare and Medicaid Services (CMS) determine the effective date of enrollment and what are the requirements for retrospective billing and how many days can you bill for services prior to the effective date of your enrollment? In this article, I will answer these questions.

Question

How is the effective date determined?

Answer

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Question
What are the retrospective billing requirements and limitations?

Answer
A physical therapist, occupational therapist or speech-language pathologist may retrospectively bill for services when:

• The supplier has met all program requirements, including state licensure requirements, and
• The services were provided at the enrolled practice location for up to—

  1. 30 days prior to their effective date if circumstances precluded enrollment in advance of
    providing services to Medicare beneficiaries, or
  2. 90 days prior to their effective date if a Presidentially-declared disaster under the Robert T.
    Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. §§5121-5206
    (Stafford Act) precluded enrollment in advance of providing services to Medicare beneficiaries.[/restrict]

Question
Can you give an example of the difference between Effective Date of Enrollment and Retrospective Billing Date?

Answer

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I hope you found this article helpful and informative. Thank you for being a Gold Member!

How to Bill for Services Provided by a Physical Therapist Assistant

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Question
For physical therapy services submitted to an insurance carrier on a 1500-claim form, how do I bill for the services provided by a physical therapist assistant?

Answer

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I hope you found this article helpful. Thank you for being a Gold Member!

How to Bill for Services Provided by an Occupational Therapy Assistant

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Question
For occupational therapy services submitted to an insurance carrier on a 1500-claim form, how do I bill for the services provided by an occupational therapy assistant?

Answer

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I hope you found this article helpful. Thank you for being a Gold Member!

NCCI Edits and Major Changes

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National Correct Coding Initiative (NCCI) edits are updated quarterly by the Centers for Medicare and Medicaid Services (CMS) and Capital Bridge, CMS’ NCCI coding contractor. Updates occur on January 1, April 1, July 1, and October 1 of each calendar year. Typically, the January 1 update sees the most additions, deletions and revisions due to new, revised and deleted CPT codes taking effect on January 1 of the calendar year.

Due to the COVID-19 Public Health Emergency as well as CMS’s expansion of telehealth services, CMS updated procedure-to-procedure (PTP) edits and Medically Unlikely Edits (MUEs) for Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes, retroactive to January 1, 2020. This announcement was posted on April 8, 2020 on the CMS website.

There have been many significant changes (well over 150) to the PTP edits applicable to physical, occupational and speech therapy services with all of them retroactive to January 1, 2020. Many of the NCCI edits have been deleted, including those that became effective January 1, 2020.

I have updated NCCI Version 26.0 for dates of service January 1, 2020 – March 31, 2020 for both the private practice setting and non-private practice settings. In addition, NCCI Version 26.1 for dates of service April 1, 2020 – June 30, 2020 has been published on my website for my Gold Members. To access the NCCI edit reference sheet, click HERE.

Billing Telehealth Incident-to a Physician

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On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule titled “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency“. In this interim final rule, CMS did add CPT codes that are typically billed by physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) as covered telehealth services; however, they did not add PTs, OTs and SLPs as telehealth providers.

This led many to ask why would CMS add these CPT codes to the list of covered therapy services if they did not add PTs, OTs and SLPs as telehealth providers? This is because the Medicare program allows physicians, physician assistants, nurse practitioners, and clinical nurse specialists who is licensed or certified by the state to furnish therapy services can bill the CPT codes that were added to the list of covered telehealth services.

A second question that arose was can a physical therapist or occupational therapist who is employed by a physician practice perform a telehealth visit and have that visit billed incident-to a physician. Right now, we do not know the answer to this question and we are seeking clarification from CMS on this question.

Watch for updates if additional information becomes available. For those of you that are a Gold Member to my website, thank you! We appreciate your business and loyalty.