Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 That is how we will monitor - we have set up a Yellow (caution approaching cap) and red (in the zone) color coding system for therapists - provided them with rounded usual visit rates based on typical 30 and 45 and 60 minute treatments and will put a manual tracking grid in when we hit YELLOW zone. Laurie Sr Director Beaufort Memorial Hospital From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 That is how we will monitor - we have set up a Yellow (caution approaching cap) and red (in the zone) color coding system for therapists - provided them with rounded usual visit rates based on typical 30 and 45 and 60 minute treatments and will put a manual tracking grid in when we hit YELLOW zone. Laurie Sr Director Beaufort Memorial Hospital From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 That is what we are currently working on- utilizing the reporting functions (creating a custom report) out of our financial system to track what we've charged using the allowable amounts. We have not come up with another way yet... Jeanne Bradshaw, PT Executive Director of Rehabilitation and Wellness Center Appalachian Regional Healthcare System P Please consider the environment before printing this e-mail From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. This document may contain information covered under the Privacy Act, 5 USC 552(a), and/or the Health Insurance Portability and Accountability Act (PL 104-191) and its various implementing regulations and must be protected in accordance with those provisions. Healthcare information is personal and sensitive and must be treated accordingly. If this correspondence contains healthcare information it is being provided to you after appropriate authorization. You, the recipient, are obligated to maintain it in a safe, secure and confidential manner. Redisclosure without additional patient consent or without legal basis is prohibited. Unauthorized redisclosure or failure to maintain confidentiality subjects you to application of appropriate sanctions. If you have received this correspondence in error, please notify the sender at once and destroy any copies you have made. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 That is what we are currently working on- utilizing the reporting functions (creating a custom report) out of our financial system to track what we've charged using the allowable amounts. We have not come up with another way yet... Jeanne Bradshaw, PT Executive Director of Rehabilitation and Wellness Center Appalachian Regional Healthcare System P Please consider the environment before printing this e-mail From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. This document may contain information covered under the Privacy Act, 5 USC 552(a), and/or the Health Insurance Portability and Accountability Act (PL 104-191) and its various implementing regulations and must be protected in accordance with those provisions. Healthcare information is personal and sensitive and must be treated accordingly. If this correspondence contains healthcare information it is being provided to you after appropriate authorization. You, the recipient, are obligated to maintain it in a safe, secure and confidential manner. Redisclosure without additional patient consent or without legal basis is prohibited. Unauthorized redisclosure or failure to maintain confidentiality subjects you to application of appropriate sanctions. If you have received this correspondence in error, please notify the sender at once and destroy any copies you have made. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 That is what we are currently working on- utilizing the reporting functions (creating a custom report) out of our financial system to track what we've charged using the allowable amounts. We have not come up with another way yet... Jeanne Bradshaw, PT Executive Director of Rehabilitation and Wellness Center Appalachian Regional Healthcare System P Please consider the environment before printing this e-mail From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. This document may contain information covered under the Privacy Act, 5 USC 552(a), and/or the Health Insurance Portability and Accountability Act (PL 104-191) and its various implementing regulations and must be protected in accordance with those provisions. Healthcare information is personal and sensitive and must be treated accordingly. If this correspondence contains healthcare information it is being provided to you after appropriate authorization. You, the recipient, are obligated to maintain it in a safe, secure and confidential manner. Redisclosure without additional patient consent or without legal basis is prohibited. Unauthorized redisclosure or failure to maintain confidentiality subjects you to application of appropriate sanctions. If you have received this correspondence in error, please notify the sender at once and destroy any copies you have made. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 FYI......and additional follow up ....many of our Outpatients are showing up today in OP Clinic and have received letters from CMS educating the beneficiaries about the therapy cap and thresholds. See below additional information for your perusal. Requests for Exceptions to the Therapy Threshold: Manual Medical Review Process Why is CMS doing this? This process is required by Section 1833(g)(5)© of the Social Security Act, as added by Section 3005 of the Middle Class Tax Relief and Job Creation Act of 2012 (MCTRJA), which was signed into law on February 22, 2012. Why has CMS not issued regulations on this process? Section 3005(d) of the MCTRJA requires implementation in a timely manner and authorizes implementation of this process via program instruction. (d) IMPLEMENTATION.-The Secretary of Health and Human Services shall implement such claims processing edits and issue such guidance as may be necessary to implement the amendments made by this section in a timely manner. Notwithstanding any other provision of law, the Secretary may implement the amendments made by this section by program instruction. What is the manual medical review threshold? $3,700 What does the $3,700 threshold represent? The threshold represents the total allowed charges under Part B for services furnished by independent practitioners, and institutional services under Part B (hospital outpatient departments, skilled nursing facilities). Does therapy provided in a critical access hospital (CAH) count? No. Services provided in a CAH are not counted and CAHs are not subject to the manual medical review provision. What are the Phases? Phase I October 1, 2012 to December 31, 2012 Phase II November 1, 2012 to December 31, 2012 Phase III December 1, 2012 to December 31, 2012 How do I know what Phase I am in? Each provider subjected to a phase will be notified via US Mail. There will also be a posting to www.CMS.gov with the providers in phase I and II. How did CMS come up with the phases? The phases were developed taking into account specific provider characteristics (e.g., claims volume and payment) and then adjusted to distribute workload evenly at the Medicare Administrative Contractor. What are the guidelines CMS contractors will use when conducting the review? The contractors will use the coverage and payment policy requirements contained within Section 220 of the Medicare Benefit Policy manual and any applicable local coverage decisions when making decisions as to whether a service shall be preapproved. How long will a contractor have to make a decision on a pre-approval request? 10 business days. What happens if a contractors decision about request for an exception is not made within 10 business days? If a manual medical review decision is not made within 10 business days, the request for exception will be deemed to be approved. If a decision was made within 10 business days and the request for an exception was denied, and the the provider furnishes the service to the beneficiary and submits a claim, what happens? The claim is not payable under Medicare, the claim will be denied, and the beneficiary will be liable for the services. Why is the beneficiary liable? Medicare only covers therapy services up to $1,880 cap in 2012. For services between $1,880 and $3,700, if the conditions for an exception are not met, the beneficiary is financially responsible. For services above the $3,700 threshold, if a request for an exception to the $3,700 threshold is not met, the beneficiary is finanancially responsible. Am I required to provide the beneficiary an Advanced Beneficiary Notice (ABN) for services above the therapy cap of $1,880? There is no legal requirement for issuance of an ABN. However, CMS strongly recommends a voluntary ABN where the provider believes that Medicare may not cover the services. How is the $3,700 calculated? The $3,700 is calculated using all outpatient therapy services provided (except those provided in Critical Access Hospitals) within the category of physical therapy/speech language therapy and then a separate category for occupational therapy services. If I am in Phase III, what happens to my claims during the timeframe of October 1, 2012 to November 30, 2012? Phase III is scheduled to begin for services expected to be furnished on or after December 1, 2012. Claims for services furnished before this time will be treated in the same manner as claims for services below the $3,700 threshold. If I am in Phase III would a Medicare contractor conduct review of my claims from October 1, 2012 to November 30, 2012? Medicare contractors have the authority to review any claim at any time. How to I know where to submit my request for exception? Please check the website of the Medicare contractor to whom you submit your claims for processing for detailed information on where to submit your request for exception for therapy services above the $3,700 threshold. Will claims that are pre-approved be guaranteed payment? Authorization does not guarantee payment. Retrospective review may still be performed. Why would a Medicare contractor review therapy that has been pre-approved? There are many reasons retrospective review would be needed after a pre-approval: clinically inappropriate modalities; patient's clinical therapy needs do not match what was reported, e.g. * Patient's functional level is greater than reported, * Patient reached functional independence more quickly than predicted. Excessive or inappropriate therapy was furnished, e.g. * therapy more often or of longer duration than is medically r/n; * therapy provided to clinical treatment area not reasonable and necessary, e.g. therapy to shoulder when knee is the issue What happens if I request pre-approval and gain approval for 20 treatment days and I actually furnish 30 treatments? The claim will be subject to prepayment medical review. What is CMS doing to educate beneficiaries about the therapy cap and the threshold? CMS will be conducting a mailing in September to beneficiaries who have received therapy services at or near the cap. The mailing will inform them of the cap and of the fact that if services above the cap are denied, that they will be financially liable. Therapy Cap Fact Sheet Medicare Part B Outpatient Therapy Cap and Exceptions Process The Middle Class Tax Relief and Job Creation Act of 2012 (H.R. 3630) was signed into law on February 22, 2012. The law extends the Medicare Part B Outpatient Therapy Cap Exceptions Process through December 31, 2012. Background The statutory Medicare Part B outpatient therapy cap for Occupational Therapy (OT) is $1,880 for 2012, and the combined cap for Physical Therapy (PT) and Speech-Language Pathology Services (SLP) is also $1,880 for 2012. This is an annual per beneficiary therapy cap amount determined for each calendar year. Medicare allowable charges,which includes both Medicare payments to providers and beneficiary coinsurance, are counted toward the therapy cap. In outpatient settings, Medicare will pay for 80 percent of allowable charges and the beneficiary is responsible for the remaining 20 percent of the amount. The therapy cap applies to all Part B outpatient therapy settings and providers including: private practices, skilled nursing facilities, home health agencies, outpatient rehabilitation facilities, and comprehensive outpatient rehabilitation facilities. Beginning this year, the therapy cap will also apply to therapy services furnished in hospital outpatient departments (HOPDs) until December 31, 2012. Before 2012, therapy provided in hospital outpatient departments did not count towards the therapy cap. The law requires an exceptions process to the therapy cap that allows providers to receive payment from Medicare for services above of the therapy cap amount. Therapy furnished by providers must always be reasonable and medically necessary, require the specialized skills of medical professional, and be justified by supporting documentation in the patient's medical record. When these conditions are met for care exceeding the therapy cap in a calendar year, which is $1,880 for 2012, a provider may submit claims for a beneficiary with a KX modifier included on the claim form. The KX modifier on the claim indicates that the requirements for an exception to the therapy cap have been met. Claims that exceed the cap and do not include the KX modifier will be denied. Manual Medical Review Process Beginning on the date of the phase-in indicated below, certain providers will be required to submit a request for an exception for therapy services above the threshold of $3,700. Similar to the therapy cap, there is a threshold of $3,700 for PT and SLP services combined and another threshold of $3,700 for OT services. Such requests for exceptions will be manually medically reviewed. To ensure a timely and orderly implementation, providers within a Medicare Administrative Contractor (MAC) jurisdiction will be divided into three Phases. Each specific provider will be notified of their status in the phase-in process. Providers will be required to submit requests for exceptions to the threshold in advance of furnishing therapy services above the threshold. The phases are as follows: * Phase I Oct 1, 2012 to December 31, 2012 * Phase II Nov 1, 2012 to December 31, 2012 * Phase III Dec 1, 2012 to December 31, 2012 o The Phase for a provider is based on CMS analysis taking into account the billing practices of the provider as well as the workload of the MAC. There will be no automatic exceptions granted for the requests fof exceptions above the threshold solely on the basis of a specific diagnosis. The contractors will use the coverage and payment policy requirements in Section 220 of the Medicare Benefit Policy manual and any applicable local coverage decision policies when making determinations for approving therapy services above the threshold. Claims received for therapy services above the threshold which have not been approved for a provider assigned within a specific phase, shall be subject to prepayment review upon receipt for payment. Requests for exceptions can be made in increments of 20 treatment days. Contractors will have 10 business days to review the request for exception to the threshold using the manual medical review process. The 10-day timeframe starts when the contractor has obtained all necessary documentation from the provider. If a contractor fails to make a decision within 10 business days of receiving a request containing all the required documentation the request will be automatically approved. Each MAC will have detailed instructions posted to their websites on how to submit a request for an exception to the threshold before September 1, 2012. Providers will be notified via US Mail before September 1, 2012 about the process to request an exception to the threshold and manual medical review process on the CMS website and which Phase the provider is assigned. Outreach and Education Letters will be sent to beneficiaries who have received $1,700 or more in therapy services in CY 2012. The letter will inform them that if services are furnished above the therapy cap of $1,880 in 2012, and the requirements for an exception are not met, then the beneficiary would be financially responsibility for these services. The letters sent to beneficiaries will also inform that that if services furnished above the $3,700 threshold have not been approved by the manual medical review process in response to submission of a request for an exception, then the beneficiary would also be financially responsible for these services. Notification letters and other outreach activities will be undertaken to inform beneficiaries and providers of the manual medical review process for therapy services above the threshold. o CMS will host an Open Door Forum on Tuesday, August 7th, 2012 at 2 pm, to provide additional information and answer any questions had on the implementation of the medical review of therapy services to begin October 1-December 31, 2012. Further questions? You can contact CMS with questions about the therapy cap and new threshold via a designated email box, at therapycapreview@.... E. Lynn MS PT Director of Rehabilitation Marlton Rehabilitation Hospital 92 Brick Rd. Marlton, NJ 08055 ext 4204 From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 FYI......and additional follow up ....many of our Outpatients are showing up today in OP Clinic and have received letters from CMS educating the beneficiaries about the therapy cap and thresholds. See below additional information for your perusal. Requests for Exceptions to the Therapy Threshold: Manual Medical Review Process Why is CMS doing this? This process is required by Section 1833(g)(5)© of the Social Security Act, as added by Section 3005 of the Middle Class Tax Relief and Job Creation Act of 2012 (MCTRJA), which was signed into law on February 22, 2012. Why has CMS not issued regulations on this process? Section 3005(d) of the MCTRJA requires implementation in a timely manner and authorizes implementation of this process via program instruction. (d) IMPLEMENTATION.-The Secretary of Health and Human Services shall implement such claims processing edits and issue such guidance as may be necessary to implement the amendments made by this section in a timely manner. Notwithstanding any other provision of law, the Secretary may implement the amendments made by this section by program instruction. What is the manual medical review threshold? $3,700 What does the $3,700 threshold represent? The threshold represents the total allowed charges under Part B for services furnished by independent practitioners, and institutional services under Part B (hospital outpatient departments, skilled nursing facilities). Does therapy provided in a critical access hospital (CAH) count? No. Services provided in a CAH are not counted and CAHs are not subject to the manual medical review provision. What are the Phases? Phase I October 1, 2012 to December 31, 2012 Phase II November 1, 2012 to December 31, 2012 Phase III December 1, 2012 to December 31, 2012 How do I know what Phase I am in? Each provider subjected to a phase will be notified via US Mail. There will also be a posting to www.CMS.gov with the providers in phase I and II. How did CMS come up with the phases? The phases were developed taking into account specific provider characteristics (e.g., claims volume and payment) and then adjusted to distribute workload evenly at the Medicare Administrative Contractor. What are the guidelines CMS contractors will use when conducting the review? The contractors will use the coverage and payment policy requirements contained within Section 220 of the Medicare Benefit Policy manual and any applicable local coverage decisions when making decisions as to whether a service shall be preapproved. How long will a contractor have to make a decision on a pre-approval request? 10 business days. What happens if a contractors decision about request for an exception is not made within 10 business days? If a manual medical review decision is not made within 10 business days, the request for exception will be deemed to be approved. If a decision was made within 10 business days and the request for an exception was denied, and the the provider furnishes the service to the beneficiary and submits a claim, what happens? The claim is not payable under Medicare, the claim will be denied, and the beneficiary will be liable for the services. Why is the beneficiary liable? Medicare only covers therapy services up to $1,880 cap in 2012. For services between $1,880 and $3,700, if the conditions for an exception are not met, the beneficiary is financially responsible. For services above the $3,700 threshold, if a request for an exception to the $3,700 threshold is not met, the beneficiary is finanancially responsible. Am I required to provide the beneficiary an Advanced Beneficiary Notice (ABN) for services above the therapy cap of $1,880? There is no legal requirement for issuance of an ABN. However, CMS strongly recommends a voluntary ABN where the provider believes that Medicare may not cover the services. How is the $3,700 calculated? The $3,700 is calculated using all outpatient therapy services provided (except those provided in Critical Access Hospitals) within the category of physical therapy/speech language therapy and then a separate category for occupational therapy services. If I am in Phase III, what happens to my claims during the timeframe of October 1, 2012 to November 30, 2012? Phase III is scheduled to begin for services expected to be furnished on or after December 1, 2012. Claims for services furnished before this time will be treated in the same manner as claims for services below the $3,700 threshold. If I am in Phase III would a Medicare contractor conduct review of my claims from October 1, 2012 to November 30, 2012? Medicare contractors have the authority to review any claim at any time. How to I know where to submit my request for exception? Please check the website of the Medicare contractor to whom you submit your claims for processing for detailed information on where to submit your request for exception for therapy services above the $3,700 threshold. Will claims that are pre-approved be guaranteed payment? Authorization does not guarantee payment. Retrospective review may still be performed. Why would a Medicare contractor review therapy that has been pre-approved? There are many reasons retrospective review would be needed after a pre-approval: clinically inappropriate modalities; patient's clinical therapy needs do not match what was reported, e.g. * Patient's functional level is greater than reported, * Patient reached functional independence more quickly than predicted. Excessive or inappropriate therapy was furnished, e.g. * therapy more often or of longer duration than is medically r/n; * therapy provided to clinical treatment area not reasonable and necessary, e.g. therapy to shoulder when knee is the issue What happens if I request pre-approval and gain approval for 20 treatment days and I actually furnish 30 treatments? The claim will be subject to prepayment medical review. What is CMS doing to educate beneficiaries about the therapy cap and the threshold? CMS will be conducting a mailing in September to beneficiaries who have received therapy services at or near the cap. The mailing will inform them of the cap and of the fact that if services above the cap are denied, that they will be financially liable. Therapy Cap Fact Sheet Medicare Part B Outpatient Therapy Cap and Exceptions Process The Middle Class Tax Relief and Job Creation Act of 2012 (H.R. 3630) was signed into law on February 22, 2012. The law extends the Medicare Part B Outpatient Therapy Cap Exceptions Process through December 31, 2012. Background The statutory Medicare Part B outpatient therapy cap for Occupational Therapy (OT) is $1,880 for 2012, and the combined cap for Physical Therapy (PT) and Speech-Language Pathology Services (SLP) is also $1,880 for 2012. This is an annual per beneficiary therapy cap amount determined for each calendar year. Medicare allowable charges,which includes both Medicare payments to providers and beneficiary coinsurance, are counted toward the therapy cap. In outpatient settings, Medicare will pay for 80 percent of allowable charges and the beneficiary is responsible for the remaining 20 percent of the amount. The therapy cap applies to all Part B outpatient therapy settings and providers including: private practices, skilled nursing facilities, home health agencies, outpatient rehabilitation facilities, and comprehensive outpatient rehabilitation facilities. Beginning this year, the therapy cap will also apply to therapy services furnished in hospital outpatient departments (HOPDs) until December 31, 2012. Before 2012, therapy provided in hospital outpatient departments did not count towards the therapy cap. The law requires an exceptions process to the therapy cap that allows providers to receive payment from Medicare for services above of the therapy cap amount. Therapy furnished by providers must always be reasonable and medically necessary, require the specialized skills of medical professional, and be justified by supporting documentation in the patient's medical record. When these conditions are met for care exceeding the therapy cap in a calendar year, which is $1,880 for 2012, a provider may submit claims for a beneficiary with a KX modifier included on the claim form. The KX modifier on the claim indicates that the requirements for an exception to the therapy cap have been met. Claims that exceed the cap and do not include the KX modifier will be denied. Manual Medical Review Process Beginning on the date of the phase-in indicated below, certain providers will be required to submit a request for an exception for therapy services above the threshold of $3,700. Similar to the therapy cap, there is a threshold of $3,700 for PT and SLP services combined and another threshold of $3,700 for OT services. Such requests for exceptions will be manually medically reviewed. To ensure a timely and orderly implementation, providers within a Medicare Administrative Contractor (MAC) jurisdiction will be divided into three Phases. Each specific provider will be notified of their status in the phase-in process. Providers will be required to submit requests for exceptions to the threshold in advance of furnishing therapy services above the threshold. The phases are as follows: * Phase I Oct 1, 2012 to December 31, 2012 * Phase II Nov 1, 2012 to December 31, 2012 * Phase III Dec 1, 2012 to December 31, 2012 o The Phase for a provider is based on CMS analysis taking into account the billing practices of the provider as well as the workload of the MAC. There will be no automatic exceptions granted for the requests fof exceptions above the threshold solely on the basis of a specific diagnosis. The contractors will use the coverage and payment policy requirements in Section 220 of the Medicare Benefit Policy manual and any applicable local coverage decision policies when making determinations for approving therapy services above the threshold. Claims received for therapy services above the threshold which have not been approved for a provider assigned within a specific phase, shall be subject to prepayment review upon receipt for payment. Requests for exceptions can be made in increments of 20 treatment days. Contractors will have 10 business days to review the request for exception to the threshold using the manual medical review process. The 10-day timeframe starts when the contractor has obtained all necessary documentation from the provider. If a contractor fails to make a decision within 10 business days of receiving a request containing all the required documentation the request will be automatically approved. Each MAC will have detailed instructions posted to their websites on how to submit a request for an exception to the threshold before September 1, 2012. Providers will be notified via US Mail before September 1, 2012 about the process to request an exception to the threshold and manual medical review process on the CMS website and which Phase the provider is assigned. Outreach and Education Letters will be sent to beneficiaries who have received $1,700 or more in therapy services in CY 2012. The letter will inform them that if services are furnished above the therapy cap of $1,880 in 2012, and the requirements for an exception are not met, then the beneficiary would be financially responsibility for these services. The letters sent to beneficiaries will also inform that that if services furnished above the $3,700 threshold have not been approved by the manual medical review process in response to submission of a request for an exception, then the beneficiary would also be financially responsible for these services. Notification letters and other outreach activities will be undertaken to inform beneficiaries and providers of the manual medical review process for therapy services above the threshold. o CMS will host an Open Door Forum on Tuesday, August 7th, 2012 at 2 pm, to provide additional information and answer any questions had on the implementation of the medical review of therapy services to begin October 1-December 31, 2012. Further questions? You can contact CMS with questions about the therapy cap and new threshold via a designated email box, at therapycapreview@.... E. Lynn MS PT Director of Rehabilitation Marlton Rehabilitation Hospital 92 Brick Rd. Marlton, NJ 08055 ext 4204 From: PTManager [mailto:PTManager ] On Behalf Of Ron Barbato Sent: Tuesday, September 04, 2012 10:18 AM To: PTManager Subject: Another CAP question Those of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@...<mailto:rbarbato%40emrmc.org> PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 Ron, We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas (Phone) mark.dwyer@... (Work Email) markdwyer87@... (Personal Email) 2aAnother CAP question Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@... Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 Ron, We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas (Phone) mark.dwyer@... (Work Email) markdwyer87@... (Personal Email) 2aAnother CAP question Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@... Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 Ron, We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas (Phone) mark.dwyer@... (Work Email) markdwyer87@... (Personal Email) 2aAnother CAP question Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going to track the CAP? I guess we could manually keep track by patient using allowable billing per CPT code? Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@... Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 4, 2012 Report Share Posted September 4, 2012 Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Thanks Mark, our EMR is Meditec, and unfortunately does not give us daily or running totals without creating a report. I may work to develop an excel spreadsheet that the front office will monitor. I , like you , wonder what 2013 holds, and putting a lot of time/expense into a system we may not need is quite a balancing act. Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Re: Re: Another CAP question Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Thanks Mark, our EMR is Meditec, and unfortunately does not give us daily or running totals without creating a report. I may work to develop an excel spreadsheet that the front office will monitor. I , like you , wonder what 2013 holds, and putting a lot of time/expense into a system we may not need is quite a balancing act. Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Re: Re: Another CAP question Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Thanks Mark, our EMR is Meditec, and unfortunately does not give us daily or running totals without creating a report. I may work to develop an excel spreadsheet that the front office will monitor. I , like you , wonder what 2013 holds, and putting a lot of time/expense into a system we may not need is quite a balancing act. Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Re: Re: Another CAP question Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Like other people have already commented on this list, I worry that putting so much effort into informing the therapists of the day to day CAP limit will only serve to create therapists that " treat to the CAP " . If hospitals are now being exposed to the CAP it could serve as an excellent indicator to Medicare what the actual therapy utilization rates are...unless of course every patient starts being seen up to - and not exceeding - $1880. Cohen PT, MS MobileRehab Pittsboro, NC > > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 I appreciate your input I am less concerned that our therapists will view the CAP as a detriment to providing skilled care, or treat to the CAP. Therefore I seek to have the most efficient processes in place to allow them to deal effectively with the requirements and timelines. Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@... PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Re: Another CAP question Like other people have already commented on this list, I worry that putting so much effort into informing the therapists of the day to day CAP limit will only serve to create therapists that " treat to the CAP " . If hospitals are now being exposed to the CAP it could serve as an excellent indicator to Medicare what the actual therapy utilization rates are...unless of course every patient starts being seen up to - and not exceeding - $1880. Cohen PT, MS MobileRehab Pittsboro, NC > > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 I appreciate your input I am less concerned that our therapists will view the CAP as a detriment to providing skilled care, or treat to the CAP. Therefore I seek to have the most efficient processes in place to allow them to deal effectively with the requirements and timelines. Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@... PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Re: Another CAP question Like other people have already commented on this list, I worry that putting so much effort into informing the therapists of the day to day CAP limit will only serve to create therapists that " treat to the CAP " . If hospitals are now being exposed to the CAP it could serve as an excellent indicator to Medicare what the actual therapy utilization rates are...unless of course every patient starts being seen up to - and not exceeding - $1880. Cohen PT, MS MobileRehab Pittsboro, NC > > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 I appreciate your input I am less concerned that our therapists will view the CAP as a detriment to providing skilled care, or treat to the CAP. Therefore I seek to have the most efficient processes in place to allow them to deal effectively with the requirements and timelines. Ron Barbato PT Administrative Director, Rehabilitation Services Program Director, Cancer Support Services Ephraim McDowell Health rbarbato@... PRIVILEGED AND CONFIDENTIAL: This transmission may contain information that is privileged subject to attorney-client privilege or attorney work product, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, then please do not read it and be aware that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately advise me, by reply e-mail, and delete this message and any attachments without retaining a copy in any form. Thank you. Re: Another CAP question Like other people have already commented on this list, I worry that putting so much effort into informing the therapists of the day to day CAP limit will only serve to create therapists that " treat to the CAP " . If hospitals are now being exposed to the CAP it could serve as an excellent indicator to Medicare what the actual therapy utilization rates are...unless of course every patient starts being seen up to - and not exceeding - $1880. Cohen PT, MS MobileRehab Pittsboro, NC > > Ron, > > We drop monthly bills in our health system so we are facing the same issue as you. We use Cerner as our EMR, and on the initial eval the therapist will key in the amount spent that we get from the Medicare Common Working File. From there our Inpatient Rehab Manager, a Cerner guru if there ever was one, has created a report that will track all charges billed to the patient at 80% of the MPFS amount and add it the Common Working File number, then subtract that sum from $1,880 to tell the therapist what is left. We plan to have the therapists screen print this report for all of their Medicare patients every Monday morning. > > The downside to our system is that it doesn't take into account the MPPR, so when our report says we are approaching the cap the reality is we have a buffer. We haven't figured out a way yet to calculate the MPPR amount, and at this point we're not planning to, at least until we know whether the cap will apply to hospitals after December 31, 2012. > > Out Inpatient Manager has figured out a way to take the functionality of the report described above and incorporate it into the daily note, too, but again, at this point we're holding off until we find out if the cap will become a permanent fixture in hospitals. If it does, then we will most likely incorporate this into the daily note. Our only concern about that, however, is the therapists becoming desensitized to seeing it day after day, but it would allow finer control since they could view the amount left on a per visit basis versus on a weekly basis. > > Mark Dwyer, PT, MHA > Director of Rehabilitation Services > Olathe Medical Center > Olathe, Kansas > (Phone) > mark.dwyer@... (Work Email) > markdwyer87@... (Personal Email) > > 2aAnother CAP question > Tue Sep 4, 2012 7:42 am (PDT) . Posted by: " Ron Barbato " adnapdetlemThose of use who " drop bills " monthly , any ideas on how you are going > to track the CAP? > I guess we could manually keep track by patient using allowable billing > per CPT code? > > Ron Barbato PT > Administrative Director, Rehabilitation Services > Program Director, Cancer Support Services > Ephraim McDowell Health > rbarbato@... > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Rick, Thank you for catching this. We were under the impression that only the Medicare payment applied to the cap, but upon receiving your email we scoured the rules/regs and found where it does say in the " Therapy Cap Fact Sheet " that the cap includes both the Medicare payments and the patient payments. I also found that same language in the August 21, 2012 beneficiary letter that CMS sent to those who have reached $1,700. In the Therapy Cap Fact Sheet is this line, " Medicare allowable charges, which includes both Medicare payments to providers and beneficiary coinsurance, are counted toward the therapy cap. " If anyone wants to find those there are posted here ==> www.cms.gov/research-statistics-data-and-systems/monitoring-programs/medical-rev\ iew/therapycap.html There is also this line in Section 10.2 A in Chapter 5 of the Medicare Claims Processing Manual, " The limits were based on incurred expenses and included applicable deductible and coinsurance. " As such, we are changing our report in Cerner to reflect 100% of the MPFS applying to the cap. Thanks again Rick. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas (Phone) mark.dwyer@... (Work Email) markdwyer87@... (Personal Email) 2bRe: Another CAP question Wed Sep 5, 2012 4:57 am (PDT) . Posted by: " Rick Gawenda " rick0905Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Rick, Thank you for catching this. We were under the impression that only the Medicare payment applied to the cap, but upon receiving your email we scoured the rules/regs and found where it does say in the " Therapy Cap Fact Sheet " that the cap includes both the Medicare payments and the patient payments. I also found that same language in the August 21, 2012 beneficiary letter that CMS sent to those who have reached $1,700. In the Therapy Cap Fact Sheet is this line, " Medicare allowable charges, which includes both Medicare payments to providers and beneficiary coinsurance, are counted toward the therapy cap. " If anyone wants to find those there are posted here ==> www.cms.gov/research-statistics-data-and-systems/monitoring-programs/medical-rev\ iew/therapycap.html There is also this line in Section 10.2 A in Chapter 5 of the Medicare Claims Processing Manual, " The limits were based on incurred expenses and included applicable deductible and coinsurance. " As such, we are changing our report in Cerner to reflect 100% of the MPFS applying to the cap. Thanks again Rick. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas (Phone) mark.dwyer@... (Work Email) markdwyer87@... (Personal Email) 2bRe: Another CAP question Wed Sep 5, 2012 4:57 am (PDT) . Posted by: " Rick Gawenda " rick0905Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted September 5, 2012 Report Share Posted September 5, 2012 Rick, Thank you for catching this. We were under the impression that only the Medicare payment applied to the cap, but upon receiving your email we scoured the rules/regs and found where it does say in the " Therapy Cap Fact Sheet " that the cap includes both the Medicare payments and the patient payments. I also found that same language in the August 21, 2012 beneficiary letter that CMS sent to those who have reached $1,700. In the Therapy Cap Fact Sheet is this line, " Medicare allowable charges, which includes both Medicare payments to providers and beneficiary coinsurance, are counted toward the therapy cap. " If anyone wants to find those there are posted here ==> www.cms.gov/research-statistics-data-and-systems/monitoring-programs/medical-rev\ iew/therapycap.html There is also this line in Section 10.2 A in Chapter 5 of the Medicare Claims Processing Manual, " The limits were based on incurred expenses and included applicable deductible and coinsurance. " As such, we are changing our report in Cerner to reflect 100% of the MPFS applying to the cap. Thanks again Rick. Mark Dwyer, PT, MHA Director of Rehabilitation Services Olathe Medical Center Olathe, Kansas (Phone) mark.dwyer@... (Work Email) markdwyer87@... (Personal Email) 2bRe: Another CAP question Wed Sep 5, 2012 4:57 am (PDT) . Posted by: " Rick Gawenda " rick0905Why do you only track 80% of the allowed amount towards the cap when it's 100% of the allowed amount that counts towards the therapy cap threshold of $1880 and then $3700? Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. http://www.gawendaseminars.com Quote Link to comment Share on other sites More sharing options...
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