Guest guest Posted December 3, 2008 Report Share Posted December 3, 2008 Todd and Tim, I disagree with Tim's interpretation and will unfortunately add to the confusion. Hopefully ongoing discussion will clarify. Transmittal 88 page 37 language for treatment note documentation reads: > " Total timed code treatment minutes and total treatment time in minutes. Total treatment time includes the minutes for timed code treatment and untimed code treatment. Total treatment time does not include time for services that are not billable (e.g., rest periods). For Medicare purposes, it is not required that unbilled services that are not part of the total treatment minutes be recorded, although they may be included voluntarily to provide an accurate description of the treatment, show consistency with the plan, or comply with state or local policies. The amount of time for each specific intervention/modality provided to the patient may also be recorded voluntarily, but contractors shall not require it, as it is indicated in the billing. The billing and the total timed code treatment minutes must be consistent. See Pub. 100-04, chapter 5, section 20.2 for description of billing timed codes; and " How do we do it? A. Treatment time: We document a total treatment time e.g.: Total treatment time = 65 minutes We do not include rest periods or bathroom breaks (nonbillable time). Think about it. If you just record time in and time out and the client takes a 10 minute bathroom break, then you are not recording actual treatment time. We do include allowed things like set up time for modalities and education time which are folded into proper codes. B. Timed codes: we document a total time code time e.g.: Total timed code = 54 minutes Although it is voluntary by the Transmittal 88 language, we have chosen to document the number of minutes for each treatment that we do. It helps us audit charts and it helps in adding up timed codes for billing. We do not carry stopwatches by the way! So in the examples above a sample Medicare treatment note (where no group therapy is being done)would read: Please note also this is a generic example done for clarity... 12/3/08 Subjective: Objective: Total treament time = 65 minutes Total timed treatment = 54 minutes (I will abbreviate the next bit for example): Manual therapy (22 minutes) Therapeutic exercise (20 mins) Neuromuscular re-ed (12 mins) Cold pack plus interferential electrical stim (11 mins) Assessment: Plan: In this example the total timed codes add up to 54 and the total treatment time to 65. Billing would be total 4 units of timed codes (per 8 minute rule) and 1 unit untimed modality. Any audit of the chart would find it easy to match the billing with the documentation. Then with a schedule of patients and charts for a given treatment day, the auditer can determine if the group therapy code was being used correctly or not. This is how we have interpreted Transmittal 88 language. I have also seen flow sheets with a row or column for total time code time in minutes and total treatment time. Reminder though that recording the time of each separate treatment (ie manual therapy 22 mins, Ther ex 15 mins) is voluntary per Transmittal 88. Unfortunately other than our old system, I am not sure how other electronic documentation systems do it. Tom Howell, P.T., M.P.T. Howell Physical Therapy Eagle, ID thowell@... Todd, > > As you probably already know... > > " The purpose of these notes is simply to create a record of all treatments and skilled interventions that are provided and to record the time of the services in order to justify the use of billing codes on the claim. " (page 36) > > Also, I have been told by Medicare consultants that time-in/time-out is not sufficient. > > We do the following: > time-in/time-out > time for one-on-one procedures > time for supervised modalities (eg: traction). > > For example: > > time-in: 8am > time-out: 9am = 4 units > > 8am to 8:30 therapeutic ex (one-on-one) > 15 minutes traction > 15 minutes e-stim = 4 units > > That way the total and the time-in/time-out minutes are consistent. > > You want to make it easy for the Medicare auditor to decide that you are not 'low hanging fruit'. > > I've found that well-designed chart templates and staff training are crucial to ensure that your therapists consistently apply these policies. > > Once they get into the habit of jotting down the time it's not too difficult. > > Get a copy of my chart template at > http://www.bulletproofpt.com/compliance-plan.htm > > Also, the reference for Transmittal 88 (page 36) is at > http://www.cms.hhs.gov/transmittals/downloads/r88bp.pdf > > > Tim > > > Tim , PT > www.BulletproofPT.com > TimRichPT@... > > > > >> >> Group, I am looking for non-grey interpretation of the > timed/unitmed/total minutes rule in transmittal 88. We are doing an internal audit and the auditor feels that start/stop times are most appropriate and reads start/stop times into the transmittal. I feel that transmittal 88 says the total time, timed minutes are all that is required. Untimed minutes are voluntary (we do include). Is there something that supplants this transmittal that says start/stop times are " best practice " ? Of course, charged units must match your recorded minutes by following the 8 min rule. >> >> Thanks. >> >> Todd Mourning, PT >> Manager of Therapy Services >> Abraham Lincoln Memorial Hospital >> 315 8th Street >> Lincoln, IL 62656 >> >> >> (direct) >> (fax) >> >> mourning.todd@... >> >> >> ________________________________ >> This message (including any attachments) contains confidential > information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this message. Any disclosure, copying, or distribution of this message, or the taking of any action based on it, is strictly > prohibited. >> >> >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted December 3, 2008 Report Share Posted December 3, 2008 Tim, In your scenario, your example stills give time in and time out. This is different from documenting total treatment time. Also you do not document total timed code time. Transmittal 88 specifically asks to document total treatment time and total time code time as my example shows. While you may infer from your example that your way of documenting can be considered the same, we read the transmittal as having to actually document, not infer, total treatment time and total timed code time. To be specific, your documentation for your example should have written out somewhere in it: Total treatment time = 60 minutes AND Total timed code time = 30 minutes (ther ex) I am only going by the example that you posted but there are very specific differences in your example and what I understand the rule to be. Tom Howell, P.T., M.P.T. thowell@... Tom, > > Please specify what part of the scenario I posted did you disagree with? > > I found your scenario very similar to mine. > > Another resource I use to help clarify the timing issue is the Part B Billing Scenarios at... > > http://www.cms.hhs.gov/TherapyServices/02_billing_scenarios.asp > > Specifically... > > > " 2. Billing - CPT Codes: Permitted > > In the same 15-minute time period, one therapist may bill for more than one therapy service occurring in the same 15-minute time period where " supervised modalities " are defined by CPT as untimed and > unattended -- not requiring the presence of the therapist (CPT codes 97010 - 97028). One or more supervised modalities may be billed in the same 15-minute time period with any other CPT code, timed or untimed, requiring constant attendance or direct one-on-one patient contact. However, any actual time the therapist uses to attend one-on-one to a patient receiving a supervised modality cannot be counted for any other service provided by the therapist. " > > > The timing issue shouldn't be all that controversial. > > I find the biggest issue is cultural - therapists don't like being told they must check their stopwatch at the beginning and the end of their one-on-one treatments. > > Unfortunately, we are paid $3.06 billion dollars per year (2006 figures) by Medicare for uncertain outcomes. > > I don't believe they trust us. > > Therefore, they micromanage our time to justify their dollars. > > Bite the bullet and get a watch. > > I wear a Timex Ironman and I check it frequently. > > Tim > www.BulletproofPT.com > timrichpt@... > > > > >> >> >> >> Group, I am looking for non-grey interpretation of the >> > timed/unitmed/total minutes rule in transmittal 88. We are doing > an >> internal audit and the auditor feels that start/stop times are most appropriate and reads start/stop times into the transmittal. I feel > that >> transmittal 88 says the total time, timed minutes are all that is required. Untimed minutes are voluntary (we do include). Is there something that supplants this transmittal that says start/stop times > are >> " best practice " ? Of course, charged units must match your recorded minutes by following the 8 min rule. >> >> >> >> Thanks. >> >> >> >> Todd Mourning, PT >> >> Manager of Therapy Services >> >> Abraham Lincoln Memorial Hospital >> >> 315 8th Street >> >> Lincoln, IL 62656 >> >> >> >> >> >> (direct) >> >> (fax) >> >> >> >> mourning.todd@<mailto:mourning.todd@> >> >> >> >> >> >> ________________________________ >> >> This message (including any attachments) contains confidential >> > information intended for a specific individual and purpose, and is >> protected by law. If you are not the intended recipient, you should delete this message. Any disclosure, copying, or distribution of > this >> message, or the taking of any action based on it, is strictly >> > prohibited. >> >> >> >> >> >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted December 3, 2008 Report Share Posted December 3, 2008 Tim, In your scenario, your example stills give time in and time out. This is different from documenting total treatment time. Also you do not document total timed code time. Transmittal 88 specifically asks to document total treatment time and total time code time as my example shows. While you may infer from your example that your way of documenting can be considered the same, we read the transmittal as having to actually document, not infer, total treatment time and total timed code time. To be specific, your documentation for your example should have written out somewhere in it: Total treatment time = 60 minutes AND Total timed code time = 30 minutes (ther ex) I am only going by the example that you posted but there are very specific differences in your example and what I understand the rule to be. Tom Howell, P.T., M.P.T. thowell@... Tom, > > Please specify what part of the scenario I posted did you disagree with? > > I found your scenario very similar to mine. > > Another resource I use to help clarify the timing issue is the Part B Billing Scenarios at... > > http://www.cms.hhs.gov/TherapyServices/02_billing_scenarios.asp > > Specifically... > > > " 2. Billing - CPT Codes: Permitted > > In the same 15-minute time period, one therapist may bill for more than one therapy service occurring in the same 15-minute time period where " supervised modalities " are defined by CPT as untimed and > unattended -- not requiring the presence of the therapist (CPT codes 97010 - 97028). One or more supervised modalities may be billed in the same 15-minute time period with any other CPT code, timed or untimed, requiring constant attendance or direct one-on-one patient contact. However, any actual time the therapist uses to attend one-on-one to a patient receiving a supervised modality cannot be counted for any other service provided by the therapist. " > > > The timing issue shouldn't be all that controversial. > > I find the biggest issue is cultural - therapists don't like being told they must check their stopwatch at the beginning and the end of their one-on-one treatments. > > Unfortunately, we are paid $3.06 billion dollars per year (2006 figures) by Medicare for uncertain outcomes. > > I don't believe they trust us. > > Therefore, they micromanage our time to justify their dollars. > > Bite the bullet and get a watch. > > I wear a Timex Ironman and I check it frequently. > > Tim > www.BulletproofPT.com > timrichpt@... > > > > >> >> >> >> Group, I am looking for non-grey interpretation of the >> > timed/unitmed/total minutes rule in transmittal 88. We are doing > an >> internal audit and the auditor feels that start/stop times are most appropriate and reads start/stop times into the transmittal. I feel > that >> transmittal 88 says the total time, timed minutes are all that is required. Untimed minutes are voluntary (we do include). Is there something that supplants this transmittal that says start/stop times > are >> " best practice " ? Of course, charged units must match your recorded minutes by following the 8 min rule. >> >> >> >> Thanks. >> >> >> >> Todd Mourning, PT >> >> Manager of Therapy Services >> >> Abraham Lincoln Memorial Hospital >> >> 315 8th Street >> >> Lincoln, IL 62656 >> >> >> >> >> >> (direct) >> >> (fax) >> >> >> >> mourning.todd@<mailto:mourning.todd@> >> >> >> >> >> >> ________________________________ >> >> This message (including any attachments) contains confidential >> > information intended for a specific individual and purpose, and is >> protected by law. If you are not the intended recipient, you should delete this message. Any disclosure, copying, or distribution of > this >> message, or the taking of any action based on it, is strictly >> > prohibited. >> >> >> >> >> >> Quote Link to comment Share on other sites More sharing options...
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