Re: directions and clarity

[Guest guest]

Damon:

While I respect Dick's thoughts on this, I don't agree with his conclusion.

I agree that there shouldn't be any difference in billing per se between

medicare and non-medicare, there is however huge differences in any rules

that they may superimpose on your practice act. Unfortunately, there are

many payors now following medicare rules and there are some payor contracts

that default to the state practice act. They key item in my opinion is to

refer to any particular contract language that you have relative to that

specific payor. Many practices simply default everything to medicare's

superimposed rules which from my perspective is very damaging to the whole

notion of an autonomous practitioner and their scope of practice.

I also agree with Dick on the use of the AMA guide. However, where we likely

disagree is on non medicare patients (where the contracts either don't

directly address the issue or they default to your practice act). Medicare

is the most restrictive. It is very explicit as to who can treat their

patients. While this is indeed unfortunate, it is reality so follow the

rules on them and don't set yourself up for potential audit problems by

grouping medicare and non-medicare patients or overlapping medicare patients

which could end up having you do manual therapy and having to bill it as

group! As to ATC's in that environment, they can't be used in any capacity

involving patient care. This actually can be extended to really any

federally funded patient.

The issue within AMA CPT code guidelines that I believe has merit is in the

definition of direct (or one on one). It is further defined as essentially

meaning visual, auditory, or manual contact. While I agree that this is

somewhat counter intuitive it is the very definition that physicians use for

allowing them to provide direct care through their support personnel (nurses

for example). I think it would be impossible for AMA to limit all codes

for physicians to explicit rules like medicare relative to one to one

because they would literally have to do every blood pressure check and HR.

Assuming that your payor isn't explicit like medicare and your practice act

allows you to use extenders (I am unfamiliar with your state's practice

act), you can use extenders for one on one codes as long as you meet the

definition within the CPT code guidelines. The larger issue really isn't

the technicality or definitions but the judgement of the physical therapist

and what should be directed and delegated. Of note, in environments in

which PT's are given the greatest autonomy (e.g. military) and least

restrictions relative to things like the medicare rules, they broadly direct

and delegate to support personnel yet still produce per capita the most

research and have the highest rate of board certification in the U.S. It is

the very model that we should strive to become which is really in part the

intention of Vision 2020.

<https://physicaltherapist.awayfind.com/larry>Larry Benz PT, DPT

PT Development LLC

CONFIDENTIALITY: This message is " Off The Record " . A lot of fancy legal

speak that none of us reads or understands is often contained here.