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...
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