I received an interesting question from a follower of mine and I thought it would be worthwhile to share the question and answer with all of you. The question was: “We have had quite a number of Medicare patients switch from inpatient status to observation status after discharge. Given that the therapy student saw the patient individually and the clinical instructor was busy with another patient and not present with the student and the Medicare patient, what should we do about the charges for the patient now that they are being billed under the patient’s Medicare Part B benefits”?
My answer to this question will also apply to any Part B patient that was seen by a therapy student without the therapist or assistant present. I will also provide scenarios when therapists can bill and be paid for therapy services when a student is involved in the treatment of a Medicare Part B patient.
The answer is those services
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Thank you, very appropriate information. How does this apply to Assistants. I believe they must also be supervised to some extent?
Supervision of assistants under Medicare Part B varies by practice setting and the state that you practice in. Watch for a future article on this topic.
While on this topic can you clarify the rule for med A in home health and skilled nursing and acute care settings?
I only speak, consult, and specialize on outpatient therapy services.
Thank you for the clarification! I was under the impression that any service provided by the student even when the PT or CCI is present in the room is not billable.
As you see, that was not correct. Thanks for reading!
How does this apply to non-medicare patients?
You would need to check with each insurance carrier regarding the utilization of students and the required supervision of the therapist.
Under the above scenario, the minutes provided by the student may not have been billed either, unless those and the minutes provided at the same time by the instructor were billed as concurrent. Under Med A, the student is seen as an extension of the therapist, so neither can bill individual MDS minutes on different patients at the same time.
The above scenario addresses Medicare Part B therapy services and not SNF Part A services. Rules and regulations are different between Medicare Part A therapy services and Medicare Part B therapy services. One example is concurrent therapy does not exist in the Medicare Part B world.
We just had an inpatient Medicare patient that a student completed the evaluation. After the patient was discharged, it was switched to an observation status and thus PT was billed under OP Part B. We had to go back and credit the patient’s account as we didn’t know it was OP Observation until after the fact. DO you agree?
Yes, I agree!