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Certification before treatment?

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Okay you consultants, impress me with your grasp of the regs:

1. Intermediaries in Ohio, Mass, and other places are requiring physician

signature/certification on the plan of treatment prior to delivery of

treatment under that plan.

2. I had assumed this was specified by a black and white regulation cite.

3. I looked for the cite today, and I just don't see it.....

The language in regs I reviewed states:

" ..if the plan is established by a physical therapist, it must be reviewed

periodically by the physician. The plan of care must be established (reduced

to writing by either professional or the provider when it makes a written

record of the oral orders) before treatment is begun. When OPT services are

continued under the same plan of treatment for a period of time, the physician

must certify at intervals of at least every 30 days that there is a continuing

need for such services. The recertification should be obtained at the time

the plan of treatment is reviewed since the same interval of at least every 30

days is required for the review of the plan. "

What I see here is that a new plan of care must be:

1. periodically reviewed by a physician

2. reduced to writing before initiation by the provider or therapist

3. the establishment of the plan occurs at the same time as a record

of oral orders.(not a signature on the plan)

Nothing in there about a signature before treatment begins....as I see it.

As far as recertification:

1. recertification must occur in 30 day intervals for continuing need

2. recerts are obtained when the plan is reviewed by the physician.

What am I missing? Could it be that the intermediaries have no regulatory

basis for this requirement for certification before treatment begins? It

seems too simple.

Tuitele, PT

Phoenix, AZ (80 degrees plus today)

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