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Physical Therapy

Presented by Regan Tyler, CPC, CPC-H, CPC-I, CPMA, CEMC

Senior Consultant & NAMAS Instructor

Agenda

• Time based billing

• Therapeutic procedure(s) documentation

• Group therapy documentation

• Legibility

• Signature requirements

• Physical therapy assistants

Time Based Billing

Documented Time (Minutes) Number Units

0-7 0

8-22 1

23-37 2

38-52 3

53-67 4

68-82 5

Must reach the half-way point of the time unit (15 min) to reach the next unit

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Therapeutic Exercise

97110 Therapeutic exercises to develop strength and

endurance, range of motion and flexibility

• Documentation must explain the actual exercise(s) done

• Time for each separate exercise should be documented

and/or repetitions

Therapeutic Exercise

• Treadmill

• Bike

• Elliptical

• Lunges

• Jumps

• Weights / weight machine

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Therapeutic Exercise

• Majority of therapists will document start and end times,

and individual exercises are counted in reps/weight

• Verify time is accurate for units billed and documentation of

specific exercise is found

Neuromuscular Reeducation

97112 Neuromuscular reeducation of movement, balance,

coordination, kinesthetic sense, posture and/or proprioception

for sitting and/or standing activities

Examples:

• Proprioceptive neuromuscular facilitation (PNF)

• Feldenkreis

• Bobath

• BAP’s boards

PNF Stretching

• Set of stretching techniques commonly used in clinical

environments to enhance both active and passive range of

motion with the ultimate goal being to optimize motor

performance and rehabilitation o Stretching then contracting the isolated muscle

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Feldenkreis

• The practitioner directs attention to habitual movement

patterns which are inefficient or strained, and teaches new

patterns using gentle, slow, repeated movements

Bobath

• Bobath concept is to promote motor learning for efficient

motor control in various environments, thereby improving

participation and function.

• This is done through specific patient handling skills to guide

patients through initiation and completion of intended tasks

o Commonly utilized after stroke

Biomechanical Ankle Platform System

Used to improve balance and proprioception in the ankle, knee, and hip

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Aquatic Therapy

97113 Aquatic therapy with therapeutic exercises

• Any type of exercise performed in a water environment

• Do not report a code for the water modality (Hubbard Tank,

whirlpool)

Gait Training

97116 Gait training (including stair climbing)

• Training the manner or style of walking, including rhythm

and speed o Stance phase

o Swing phase

o Double support phase

Massage

97124 Massage, including effleurage, petrissage and/or

tapotement (stroking, compression, percussion)

Effleurage: light massage stroke used in Swedish massage prior

to deep tissue work

Petrissage: deep and compressing massage movements

Tapotement: rhythmic percussion used in massage

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Therapeutic Procedures

• All codes in range (97110-97124) billed in 15 minute units

• 7 minutes or less is not reportable

• In and out times not required but individual modality times

are

Manual Therapy

97140 Manual Therapy techniques (eg,

mobilization/manipulation, manual lymphatic drainage,

manual traction), 1 or more regions, each 15 minutes

Hands-on therapy techniques.

Manual Therapy

• Connective tissue massage

• Joint mobilization and manipulation

• Manual lymphatic drainage

• Manual traction

• Passive range of motion

• Soft tissue mobilization

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Supervised Modalities

97010 hot or cold packs

97012 traction, mechanical

97014 electrical stimulation (unattended)

97016 vasopneumatic devices

97018 paraffin bath

97022 whirlpool

97024 diathermy (microwave)

97026 infrared

97018 ultraviolet

Supervised Modalities

• PT remains in the room and available but does not need to

be one-on-one

• No time associated with these services

Constant Attendance Modalities

97032 electrical stimulation (manual)

97033 iontophoresis

97034 contrast baths

97035 ultrasound

97036 Hubbard tank

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Constant Attendance Modalities

• All codes are billed in 15 minute increments

• Require one-on-one attendance by provider

Group Therapy

97150 Therapeutic procedure(s), group (2 or more individuals)

The health care provider supervises group activities (two or

more patients/clients) during therapeutic procedures on land

or in the aquatic environment. The patients/clients do not have

to be performing the same activity simultaneously; however,

the need for skilled intervention must be documented. This

code can be reported once for each group participant.

Group Therapy

• No time associated with group therapy

• Can be reported on the same day as one-on-one services

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Group Therapy

Per CMS:

Group therapy consists of simultaneous treatment of two or

more patients who may or may not be doing the same

activities. If the therapist is dividing attention among the

patients, providing only brief, intermittent personal contact, or

giving the same instructions to two or more patients at the

same time, it is appropriate to bill each patient one unit of

group therapy, 97150.

Group Therapy

• In order to bill for therapeutic exercise/activities that require

one-on-one care from the PT, time must not be split between

patients.

• It is appropriate to spent time in chunks, for example 4

minutes on one exercise, have that patient do a

unsupervised modality for 10 minutes, return and do 8

additional minutes of exercise.

• If time cannot be directed one-on-one, group therapy should

be reported

Legibility

• All documentation must be legible o If not legible one could dictate for clarity and submit both notes when requested

• Create an “approved” acronym and symbol list

• Have a standard for documenting times and repetitions o Are you capturing in and out times? Is everyone?

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Legibility

• If you don’t know what an acronym is, just ask

• If you don’t know if it’s a time (minutes) or a repetition, just

ask

Physician Order

• During an audit you should be verifying there is an

appropriate physician referral for services

• Verify appropriate communication occurs between the PT

and physician

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Signature Requirements

• Like all medical records, PT records must be appropriately

signed

• If handwritten notes, verify a signature log is available

Physical Therapy Assistants

• Licensed to work in all states

• Licensed in some states to work unsupervised

• CMS requires PTAs to be supervised

Physical Therapy Assistants

Per CMS:

“A physical therapist must supervise PTA’s. The level and

frequency of supervision differs by setting and by state or local

law. General supervision is required for PTA’s in all settings

except private practice, which requires direct supervision,

unless state practice requirements are more stringent. In

these cases, state or local requirements must be

followed. See specific settings for details…”

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Physical Therapy Assistants

General supervision

• The procedure is furnished under the physician’s overall direction and

control in the office setting.

• The physician’s presence is not required during the performance of the

procedure.

• The physician is responsible for ensuring that the non-physician

personnel who actually perform the diagnostic procedure are trained

and are responsible for ensuring the maintenance of the necessary

equipment and supplies to perform the tests.

Physical Therapy Assistants

Direct supervision

• A physician must be present in the office suite and

immediately available to furnish assistance and direction

throughout the performance of the procedure in the office

setting.

• The physician does not have to be present in the room when

the procedure is performed.

Physical Therapy Assistants

• The services of PTAs used when providing covered therapy

benefits are included as part of the covered service. These

services are billed by the supervising physical therapist.

PTAs may not provide evaluation services, make clinical

judgments or decisions or take responsibility for the service.

They act at the direction and under the supervision of the

treating physical therapist and in accordance with state

laws.

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Physical Therapy Assistants

• A physical therapist must supervise PTAs. The level and frequency of

supervision differs by setting (and by state or local law). General

supervision is required for PTAs in all settings except private practice

(which requires direct supervision) unless state practice requirements

are more stringent, in which case state or local requirements must be

followed. See specific settings for details. For example, in clinics,

rehabilitation agencies, and public health agencies, 42CFR485.713

indicates that when a PTA provides services, either on or off the

organization’s premises, those services are supervised by a qualified

physical therapist who makes an onsite supervisory visit at least once

every 30 days or more frequently if required by state or local laws or

regulation.

Physical Therapy Assistants

• The services of a PTA shall not be billed as services incident

to a physician/NPP’s service, because they do not meet the

qualifications of a therapist.

PT Modifiers

GN Services delivered under an outpatient speech-

language pathology plan of care;

GO Services delivered under an outpatient occupational

therapy plan of care; or,

GP Services delivered under an outpatient physical therapy

plan of care.

KX: Cap exception

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Therapy Cap

Outpatient financial limitations are listed on the CMS website

• Publication 100-04, Chapter 5, Section 10.2

• $1920 – PT and SLP combined

• $1920 – OT

Modifier KX

• Documentation must be found to support the requirement

of continued therapy services over the therapy cap

• Use of modifier KX does not require documentation to be

sent

• Patients receiving over $3840 total in therapy services will

prompt a manual review by CMS

Can we correlate time per service to the breakdown of activities?

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Audit Reminders

• Verify referral from MD

• Verify continuation of plan from MD

• Notes complete, legible and signed and include progress

• Timed codes supported (Including 1 patient at a time)

• PTA’s used appropriate

• CMS – modifiers supported by documentation

AAPC CEU #

38875RGS

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National Alliance of

Medical Auditing

Specialists

10401 Kingston Pike, Knoxville, TN 37922

P: 1-877-418-5564 F: 1-865-531-0722

Web: www.NAMAS.co Email: namas@namas-auditing.com