Guest guest Posted September 12, 2011 Report Share Posted September 12, 2011 Hi, Mark - A Physical Therapist in Private Practice (PTPP) is only one Medicare provider type. A PTPP must provide direct supervision of PTAs. There is some variance of opinion on whether that means " line of sight " or " in the same room " . Physical therapy services provided in physician offices must meet all of the Medicare standards except licensure of the therapist. That means the service must be provided by someone with a degree in physical therapy, who prepares a full evaluation, gets a plan of care certified, prepares daily visit notes and a discharge summary. If they supervise a PTA, it must be under the same standards as a PTPP. In fact, Medicare expects such PTs to obtain an NPI number and get a provider number. So, services billed under either PTPP or " incident to " need to have a PT present, even when a PTA is doing the work. That includes those services provided in the patient's home. It's all Part B. As far as rationale... Well, it's a Federal program, and we should never expect them to be rational. If they were rational, we'd have been recognized as physicians years ago. Hope that helps! Dick Hillyer, DPT Dr. Hillyer, PT,DPT,MBA,MSM Hillyer Consulting Cape Coral, FL 33914 _____ From: PTManager [mailto:PTManager ] On Behalf Of Mark Niles Sent: Monday, September 12, 2011 8:54 AM To: PTManager Subject: PTA supervision Can someone explain the rational of why a pta has to have a PT on site in private practice, not when incident to and no pta can work doing home visits with a PT doing and billing for home visits part B? or is it still that way? Mark Niles PT, MS, CSCS Orthopedic Specialists PA mniles@... <mailto:mniles%40orthospecpa.net> x3 fax This message, together with any attachments, is intended only for the addressee. It may contain information which is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, use, or any action or reliance on this communication is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately by telephone ( x3) or by return e-mail and delete the message, along with any attachments From: PTManager <mailto:PTManager%40yahoogroups.com> [mailto:PTManager <mailto:PTManager%40yahoogroups.com> ] On Behalf Of Northwest Rehabilitation Sent: Saturday, September 10, 2011 6:29 PM To: PTManager Subject: support staff FTE per therapist FTE Mike - I am forwarding an email that I saw years ago (2006), posted on PTManager. This is not my data, yet I agree with the parameters and our clinic fits within the projections outlined. I do know the source of the email, yet I will let that individual identify themselves if they should so choose. So...here you go: ............................................................................. ....................................... Subject: RE: Re: Support Staffing To: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> Date: Saturday, August 12, 2006, 7:13 AM We've done a few of these projects in the past, and here's a sort of rule of thumb: (Office staff FTEs) + (Clinical FTEs) = Total FTEs Office staff: A " step model " driven by daily patient visits and managed over each two-week pay period. (This model is for an OP clinic which handles all telephoning, intake, authorization, appointments, charge entry, medical records, chart assembly/disassembly. They don't print, assemble, or mail bills or receive payments. Obviously, individual cases will call for more detailed calculations.) 0-25 visits/day - 2 staff 26-75 visits/day - 3 staff 76-100 visits/day - 4 staff Clinical Staff: In a mainly 1:1 clinic with 45 minute visits (1-hour evals). Based on the premise that clincal staff are there to see patients, but that there are evil events, such as no-shows. 3 billable 15-minute units per paid manhour. 75% of paid time is billable. 6 hours of patient care per 8-hour day. Tech/aide staff is only present to enable therapists and clinicians to see paying patients, so their hours are included, but they, of course, have no billable productivity. So, a week with, say, 400 visits would average 80/day. Visits average 3 units of One-to-One care. (80 visits/day X 3units/visit=240 units/day) That's 80 manhours/day, or 10 clinicians (aggregate Therapist/Assistant/Tech). A smaller clinic with half those visits would have 5 clinicians and 3 office staff. Hope that helps! ............................................................................. ... Mike Salem, OR Mike Studer,PT,MHS,NCS, CEEAA 2011 Neurology Section Clinician of the Year President, Northwest Rehabilitation Associates Inc. Serving You With Specialist Care and a Personal Touch Phone: Fax: mike@... <mailto:mike%40northwestrehab.com> <mailto:mike%40northwestrehab.com> www.northwestrehab.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 13, 2011 Report Share Posted September 13, 2011 Hello Mark, You have to differentiate between Private practice which is a supplier of services and other Part B providers who are institutional providers. Both come under the Medicare Part B regulations, however the supplier comes under the regulations that dictate Physician services. The direct supervision that is required for private practice is defined as the therapist (or physician for incident-to) being present in the same office suite and being immediately available to the assistant when they are providing care. In all other Part B provider settings, the supervision is general and the provider can bill for the services of the PTA when they provide services in the patient's home or the clinic without the therapist actually being present. When we look at the guidelines for physician services, their " assistants " are non-physician practitioners, i.e. Nurse Practitioners, Physician Assistants and Clinical Nurse Specialist. The difference now is that these assistants can have their own provider number and bill for their services at a lesser price when the physician is not available, or bill incident-to for the higher reimbursement when the physician is on site. Our assistants are not allowed their own provider number, therefore they have to always bill their services " incident-to " the supervising therapist who is the supplier of those services to Medicare. A physician cannot use the services of a PTA " incident-to " as the PTA must always be under the supervision of a licensed therapist. When therapists work for physicians " incident-to " they are effectively giving up their license and working under that of the physician. Hope this helps in clearing up the confusion. It's all based in statute. ine ine M. o, PT Owner Encompass Consulting & Education, LLC 8114 NW 100th Terrace, Tamarac, FL 33321-1259 We work hard to make sure you are " getting it right from the start " . Visit our website at <http://www.encompassmedicare.com/> www.encompassmedicare.com and see what we can do for you. While there sign up for our free e-mail Newsletter " Medicare News and Rules for Therapists " . We specialize in consulting services, seminars and customized education services to providers of Medicare rehabilitation therapy and related services. NOTICE: This communication is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this communication is not the intended recipient or the employee or agent responsible for delivering the communication, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify me immediately by replying to this email. From: PTManager <mailto:PTManager%40yahoogroups.com> [mailto:PTManager <mailto:PTManager%40yahoogroups.com> ] On Behalf Of Mark Niles Sent: Monday, September 12, 2011 8:54 AM To: PTManager <mailto:PTManager%40yahoogroups.com> Subject: PTA supervision Can someone explain the rational of why a pta has to have a PT on site in private practice, not when incident to and no pta can work doing home visits with a PT doing and billing for home visits part B? or is it still that way? Mark Niles PT, MS, CSCS Orthopedic Specialists PA mniles@... <mailto:mniles%40orthospecpa.net> <mailto:mniles%40orthospecpa.net> x3 fax This message, together with any attachments, is intended only for the addressee. It may contain information which is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, use, or any action or reliance on this communication is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately by telephone ( x3) or by return e-mail and delete the message, along with any attachments From: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> [mailto:PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> ] On Behalf Of Northwest Rehabilitation Sent: Saturday, September 10, 2011 6:29 PM To: PTManager Subject: support staff FTE per therapist FTE Mike - I am forwarding an email that I saw years ago (2006), posted on PTManager. This is not my data, yet I agree with the parameters and our clinic fits within the projections outlined. I do know the source of the email, yet I will let that individual identify themselves if they should so choose. So...here you go: ............................................................................. ....................................... Subject: RE: Re: Support Staffing To: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> Date: Saturday, August 12, 2006, 7:13 AM We've done a few of these projects in the past, and here's a sort of rule of thumb: (Office staff FTEs) + (Clinical FTEs) = Total FTEs Office staff: A " step model " driven by daily patient visits and managed over each two-week pay period. (This model is for an OP clinic which handles all telephoning, intake, authorization, appointments, charge entry, medical records, chart assembly/disassembly. They don't print, assemble, or mail bills or receive payments. Obviously, individual cases will call for more detailed calculations.) 0-25 visits/day - 2 staff 26-75 visits/day - 3 staff 76-100 visits/day - 4 staff Clinical Staff: In a mainly 1:1 clinic with 45 minute visits (1-hour evals). Based on the premise that clincal staff are there to see patients, but that there are evil events, such as no-shows. 3 billable 15-minute units per paid manhour. 75% of paid time is billable. 6 hours of patient care per 8-hour day. Tech/aide staff is only present to enable therapists and clinicians to see paying patients, so their hours are included, but they, of course, have no billable productivity. So, a week with, say, 400 visits would average 80/day. Visits average 3 units of One-to-One care. (80 visits/day X 3units/visit=240 units/day) That's 80 manhours/day, or 10 clinicians (aggregate Therapist/Assistant/Tech). A smaller clinic with half those visits would have 5 clinicians and 3 office staff. Hope that helps! ............................................................................. ... Mike Salem, OR Mike Studer,PT,MHS,NCS, CEEAA 2011 Neurology Section Clinician of the Year President, Northwest Rehabilitation Associates Inc. Serving You With Specialist Care and a Personal Touch Phone: Fax: mike@... <mailto:mike%40northwestrehab.com> <mailto:mike%40northwestrehab.com> <mailto:mike%40northwestrehab.com> www.northwestrehab.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 13, 2011 Report Share Posted September 13, 2011 Thank you Dick and ine for your insight. Do any of you see any change insight in having PTA getting NPI's? Mark Niles PT, MS, CSCS Orthopedic Specialists PA mniles@... x3 fax This message, together with any attachments, is intended only for the addressee. It may contain information which is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, use, or any action or reliance on this communication is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately by telephone ( x3) or by return e-mail and delete the message, along with any attachments From: PTManager [mailto:PTManager ] On Behalf Of ine o Sent: Tuesday, September 13, 2011 8:09 AM To: PTManager Subject: RE: PTA supervision Hello Mark, You have to differentiate between Private practice which is a supplier of services and other Part B providers who are institutional providers. Both come under the Medicare Part B regulations, however the supplier comes under the regulations that dictate Physician services. The direct supervision that is required for private practice is defined as the therapist (or physician for incident-to) being present in the same office suite and being immediately available to the assistant when they are providing care. In all other Part B provider settings, the supervision is general and the provider can bill for the services of the PTA when they provide services in the patient's home or the clinic without the therapist actually being present. When we look at the guidelines for physician services, their " assistants " are non-physician practitioners, i.e. Nurse Practitioners, Physician Assistants and Clinical Nurse Specialist. The difference now is that these assistants can have their own provider number and bill for their services at a lesser price when the physician is not available, or bill incident-to for the higher reimbursement when the physician is on site. Our assistants are not allowed their own provider number, therefore they have to always bill their services " incident-to " the supervising therapist who is the supplier of those services to Medicare. A physician cannot use the services of a PTA " incident-to " as the PTA must always be under the supervision of a licensed therapist. When therapists work for physicians " incident-to " they are effectively giving up their license and working under that of the physician. Hope this helps in clearing up the confusion. It's all based in statute. ine ine M. o, PT Owner Encompass Consulting & Education, LLC 8114 NW 100th Terrace, Tamarac, FL 33321-1259 We work hard to make sure you are " getting it right from the start " . Visit our website at <http://www.encompassmedicare.com/> www.encompassmedicare.com and see what we can do for you. While there sign up for our free e-mail Newsletter " Medicare News and Rules for Therapists " . We specialize in consulting services, seminars and customized education services to providers of Medicare rehabilitation therapy and related services. NOTICE: This communication is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this communication is not the intended recipient or the employee or agent responsible for delivering the communication, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify me immediately by replying to this email. From: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> [mailto:PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> ] On Behalf Of Mark Niles Sent: Monday, September 12, 2011 8:54 AM To: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> Subject: PTA supervision Can someone explain the rational of why a pta has to have a PT on site in private practice, not when incident to and no pta can work doing home visits with a PT doing and billing for home visits part B? or is it still that way? Mark Niles PT, MS, CSCS Orthopedic Specialists PA mniles@... <mailto:mniles%40orthospecpa.net> <mailto:mniles%40orthospecpa.net> <mailto:mniles%40orthospecpa.net> x3 fax This message, together with any attachments, is intended only for the addressee. It may contain information which is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, use, or any action or reliance on this communication is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately by telephone ( x3) or by return e-mail and delete the message, along with any attachments From: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> [mailto:PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> ] On Behalf Of Northwest Rehabilitation Sent: Saturday, September 10, 2011 6:29 PM To: PTManager Subject: support staff FTE per therapist FTE Mike - I am forwarding an email that I saw years ago (2006), posted on PTManager. This is not my data, yet I agree with the parameters and our clinic fits within the projections outlined. I do know the source of the email, yet I will let that individual identify themselves if they should so choose. So...here you go: ............................................................................. ....................................... Subject: RE: Re: Support Staffing To: PTManager <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> <mailto:PTManager%40yahoogroups.com> Date: Saturday, August 12, 2006, 7:13 AM We've done a few of these projects in the past, and here's a sort of rule of thumb: (Office staff FTEs) + (Clinical FTEs) = Total FTEs Office staff: A " step model " driven by daily patient visits and managed over each two-week pay period. (This model is for an OP clinic which handles all telephoning, intake, authorization, appointments, charge entry, medical records, chart assembly/disassembly. They don't print, assemble, or mail bills or receive payments. Obviously, individual cases will call for more detailed calculations.) 0-25 visits/day - 2 staff 26-75 visits/day - 3 staff 76-100 visits/day - 4 staff Clinical Staff: In a mainly 1:1 clinic with 45 minute visits (1-hour evals). Based on the premise that clincal staff are there to see patients, but that there are evil events, such as no-shows. 3 billable 15-minute units per paid manhour. 75% of paid time is billable. 6 hours of patient care per 8-hour day. Tech/aide staff is only present to enable therapists and clinicians to see paying patients, so their hours are included, but they, of course, have no billable productivity. So, a week with, say, 400 visits would average 80/day. Visits average 3 units of One-to-One care. (80 visits/day X 3units/visit=240 units/day) That's 80 manhours/day, or 10 clinicians (aggregate Therapist/Assistant/Tech). A smaller clinic with half those visits would have 5 clinicians and 3 office staff. Hope that helps! ............................................................................. ... Mike Salem, OR Mike Studer,PT,MHS,NCS, CEEAA 2011 Neurology Section Clinician of the Year President, Northwest Rehabilitation Associates Inc. Serving You With Specialist Care and a Personal Touch Phone: Fax: mike@... <mailto:mike%40northwestrehab.com> <mailto:mike%40northwestrehab.com> <mailto:mike%40northwestrehab.com> <mailto:mike%40northwestrehab.com> www.northwestrehab.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 14, 2011 Report Share Posted September 14, 2011 Actually, PTAs can get their own NPI numbers as we found out in Kansas last year when BCBSKS began requiring private practice clinics to report when PTAs treated patients by listing the PTA's NPI numbers on the claim. Per ine's email below, the issue with Medicare is that they do not yet recognize PTAs as individual providers hence their need to bill incident to the PT. But PTAs can get NPI numbers. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas markdwyer87@... Re: PTA supervision Posted by: " ine o " pmfranko@... watzitsname Tue Sep 13, 2011 5:33 am (PDT) Hello Mark, You have to differentiate between Private practice which is a supplier of services and other Part B providers who are institutional providers. Both come under the Medicare Part B regulations, however the supplier comes under the regulations that dictate Physician services. The direct supervision that is required for private practice is defined as the therapist (or physician for incident-to) being present in the same office suite and being immediately available to the assistant when they are providing care. In all other Part B provider settings, the supervision is general and the provider can bill for the services of the PTA when they provide services in the patient's home or the clinic without the therapist actually being present. When we look at the guidelines for physician services, their " assistants " are non-physician practitioners, i.e. Nurse Practitioners, Physician Assistants and Clinical Nurse Specialist. The difference now is that these assistants can have their own provider number and bill for their services at a lesser price when the physician is not available, or bill incident-to for the higher reimbursement when the physician is on site. Our assistants are not allowed their own provider number, therefore they have to always bill their services " incident-to " the supervising therapist who is the supplier of those services to Medicare. A physician cannot use the services of a PTA " incident-to " as the PTA must always be under the supervision of a licensed therapist. When therapists work for physicians " incident-to " they are effectively giving up their license and working under that of the physician. Hope this helps in clearing up the confusion. It's all based in statute. ine ine M. o, PT Owner Encompass Consulting & Education, LLC 8114 NW 100th Terrace, Tamarac, FL 33321-1259 Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 20, 2011 Report Share Posted September 20, 2011 Can PTA's treat patient's in the home under an ORF or CORF setting with " incident to " the physical therapist. And if so, is it possible to move from a PTPP to an ORF and what is needed to do this transition. - Physical Therapy Delray beach, Florida From: PTManager [mailto:PTManager ] On Behalf Of Mark Dwyer Sent: Wednesday, September 14, 2011 9:53 AM To: PTManager Subject: Re: PTA supervision Actually, PTAs can get their own NPI numbers as we found out in Kansas last year when BCBSKS began requiring private practice clinics to report when PTAs treated patients by listing the PTA's NPI numbers on the claim. Per ine's email below, the issue with Medicare is that they do not yet recognize PTAs as individual providers hence their need to bill incident to the PT. But PTAs can get NPI numbers. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas markdwyer87@... <mailto:markdwyer87%40me.com> Re: PTA supervision Posted by: " ine o " pmfranko@... <mailto:pmfranko%40encompassmedicare.com> watzitsname Tue Sep 13, 2011 5:33 am (PDT) Hello Mark, You have to differentiate between Private practice which is a supplier of services and other Part B providers who are institutional providers. Both come under the Medicare Part B regulations, however the supplier comes under the regulations that dictate Physician services. The direct supervision that is required for private practice is defined as the therapist (or physician for incident-to) being present in the same office suite and being immediately available to the assistant when they are providing care. In all other Part B provider settings, the supervision is general and the provider can bill for the services of the PTA when they provide services in the patient's home or the clinic without the therapist actually being present. When we look at the guidelines for physician services, their " assistants " are non-physician practitioners, i.e. Nurse Practitioners, Physician Assistants and Clinical Nurse Specialist. The difference now is that these assistants can have their own provider number and bill for their services at a lesser price when the physician is not available, or bill incident-to for the higher reimbursement when the physician is on site. Our assistants are not allowed their own provider number, therefore they have to always bill their services " incident-to " the supervising therapist who is the supplier of those services to Medicare. A physician cannot use the services of a PTA " incident-to " as the PTA must always be under the supervision of a licensed therapist. When therapists work for physicians " incident-to " they are effectively giving up their license and working under that of the physician. Hope this helps in clearing up the confusion. It's all based in statute. ine ine M. o, PT Owner Encompass Consulting & Education, LLC 8114 NW 100th Terrace, Tamarac, FL 33321-1259 Quote Link to comment Share on other sites More sharing options...
Recommended Posts
Join the conversation
You are posting as a guest. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.