RE: Medicare A and Medicare B tx in same gym

[Guest guest]

Noreen,

Many times expectations are set based on myth or company policy that is not a

regualtion. But before we call it " Nonsense " we need to recognize that often

there was a legitimate reason for setting rules. You will not likely find a

Medicare regulation or rule that states you cannot treat a Part A in the same

room as an outpatient Part B. An SNF is not regulated only by Medicare rules.

There are also licensing regulations at both the state and federal level that

dictate what can or cannot be done in an SNF. There may be regulations that

touch on this in your state (you did not indicate what state you are from). You

may not find a licensing regulation that addresses this either, however it's

important to note that these regulations are open to interpretation by the

surveyor/inspector. Here in California there was a state surveyor who cited

facilities for treating outpatients jointly with inpatients. Her rationale was

that the SNF is the place of residence for the inpatients so outsiders should

not be brought into their area of treatment and it posed a possible infection

control issue for both the inpatient and outpatient. Make sure you do not have a

similar " interpretation " in your area. The solution was to post separate

inpatient and outpatient hours. By having the patients in the gym at separate

times there were none of the concerns.

Use of the 700 form has not been required for many years. The information on it

is required. There are many who make the rationalization that if we use the 700

it will not only provide all the necessary information but it is in a format

that potential reviewers are familiar with so they will more easily find what

they are looking for. Many of the automated rehab documentation systems produce

an evaluation very similar to the 700, in support of this philosophy.

You are correct in stating that certification for Part A is for the totality of

the patient care not separate for each discipline. There are facilities I am

working with who have had therapy services denied, during a records review,

because there was no physician signature on the evaluation. This has happened

both when reviewed by a MAC and a RAC. The rationale was that the signature was

evidence and authorization that the physician approved of and participated in

the development of the treatment plan. So while techically it is not a

certification, it is an approval by the physician. As a result many are having

the physician sign both Part A and Part B evaluation/700 forms.

Check with your Rehab Company about why they are requiring these items. They may

be addressing an experience you have not been exposed to. It may prevent a

denial of payment or licensing deficiency in the future.

Or it could all be nonsense and a waste of time. LOL

Ron Wall

Axiom Healthcare Group

Ontario, CA

To: ptmanager ; geriatricspt

From: noreen_e_v@...

Date: Mon, 2 Jul 2012 20:21:39 -0400

Subject: Medicare A and Medicare B tx in same gym

Group,

I have the misfortune to have to deal with a Rehab Company coming into my SNF.

These people do not seem to know what they are doing. They are trying to tell us

that inpatient Part B residents can not be treated in the same PT/OT gym as

inpatient Part B patients. Now I know that outpatient need a separate entrance,

separate changing area, etc. I have never heard that an inpatient Part A can not

be treated by one therapist in a gym while a Part B inpatient is treated by

another therapist, both 1:1.

Now honestly how many facilities even HAVE 2 separate PT or OT gyms? These

people are still using the HCFA 700 form to " recert " part A residents. WHO does

that? HCFA doesn't even exist anymore , it is now CMS. When a Part A resident is

certified by the MD it is for the SNF stay, no separate PT or OT or SLP

" certification is needed. It is a waste of time and paper!

What I am hoping someone can provide me is documentation that what they are

saying is nonsense! I am about to lose my mind. I feel like I have traveled back

in time.

Noreen Vollmer, PT

Director of Rehab Services

Lutheran Care