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COTA Thoughts

Reimbursement Guidelines

Published June 6, 2008 9:32 AM by Tim Banish

Medicare has some very specific rules that we all have to follow in regards to performing treatments and submitting the billing for time spent with patients. Ever since the advent of PPS there have been many different definitions, or ways people try to read between the lines, to make the rules bend to their liking.

One fact that has always been true, without question, is what constitutes fraud. Billing for treatment time not actually spent with the patient, billing for treatment not given, and billing excess time for groups and co-treats are probably the ones most abused. I'm sure there are many more I can't even think of, but one thing I do know is being caught for Medicare fraud will cost you your license, a possible fine or maybe even jail time.

Reading through a few blogs this past week, I found a few entries by some people concerned with the actions of another therapist they know. It seems like some therapists have forgot the code of ethics they agreed to abide by. I see one entry where a therapist has been coming to work, seeing their caseload of patients for about 15 minutes each, but billing them for an entire treatment. Another entry from the blogs is one therapist who works about 3 hours, bills for an eight hour day, and then heads off to work for another company. Either of these are cases of classic fraud, and when a Medicare audit is done I'm sure this will lead to some corrective action for the guilty parties. Therapists who work in such a poor ethical manner are not only stealing from their patients, but are probably stealing a job from another therapist.

However, my other concern here is for the people who are aware of the fraud happening. Being aware that someone is committing fraud but doing nothing about it makes you just as guilty. This too can cost a person their license, subject you to fines, or possibly lead to some time in jail. None of these are worth the risk of covering up for someone who is cheating the system.

On top of any of these concerns though, is the fact that scenarios like this is what led us into the tight reimbursement guidelines we have today. In the past, stories like the group who used to assemble their 12-18 patients in a therapy room, pass modalities around for 2 hours, then leave and bill this as 8 units of therapy for every patient was one of the abuses that caused Medicare to change the rules. New cuts are already being talked about, and our field is already tough enough to remain profitable in. If you or anyone you know is guilty of fraudulent billing, you'll be the ones to blame when the new cuts make things tougher. However, I'm sure you'll also be the first ones to whine too.

Until next time, hope all your thoughts are good,

Tim

7 comments

What are the medicare rules regarding billing time for cotreats.  ie.  OT and PT spend 1 hour together treating a pt.  Is that 30 min for each disipline?  

Miriam, rehab - OTR, LTC September 3, 2008 11:01 PM
Baltimore MD

HI , I THINKING ABOUT  BECOMING A COTA.  I'M IN A TWO YEAR PROGRAM IS IT WORTH MY TIME. PLEASE HELP ME

THANK YOU

kisha, pct July 18, 2008 10:36 PM
atlanta GA

From what I've seen, big contracting companies are taking over and trying to dictate plans of care as to type of treatment, length of stay and rug level just to keep administrators happy.  The last straw was when the district manager (PTA) banned OTs from using PAMs.  His excuse was OT's were not educated enough despite the fact we met state requirements.  The sad part is I know this is wrong but I didn't know what to do.  I've since changed settings, but I know this is still my problem

Dee, SNF - OT June 30, 2008 9:32 PM
FL

Judy-

Tough call, but my guess is to move on as you're already trying to do. Companies like this are all around. Inform others to avoid them, and when they can't hire staff, they'll go away.

Tim Banish, LTC - COTA/L June 17, 2008 8:08 PM
Cincinnati OH

What do you do when the "wonderful" company that took over the building your in makes you uncomfortable on their take of the guidelines.  They have taken over all but one building in the area, because they way undercut the part A cost to the facility, then expect you to see 4 part A's at a time reguardless of what level of treatment the person needs.  Some patients need more one on one than others.  But if you don't meet their profit guidelines you get reprimanded and so on and so forth.  I am currently looking for a new job.  They have only been here about a month, but I don't like the way they run things or what they are doing.  I will be driving over an hr a way because of the number of places they have taken over.  They have all the advisors and lawyers to tell you they are right.  But it still doesn't seem right.  

Judy, COTA June 14, 2008 8:53 PM
Columbus MS

Thanks Laurie-

Positive change is needed. I wish I had the answer to initiate it.

Tim

Tim Banish, LTC - COTA/L June 10, 2008 6:09 PM
Cincinnati OH

Nicley put Tim!!!  What you described has seemed to become the norm with pt's  being billed for more hrs then therapist  in the facility due to seeing several pt's a once.  And group therapy what  a stretch with what I have heard PT was billing for in  cotreatment group's with OT.   I would love to read the actual guidlines on group therapy for myself.  I have recently left a job beacuse the rehab director was pushing for  what I felt was unethical practice.    Where has the quality gone???? What needs to be done to get it back!! I really hope medicare starts looking into therapy delivery and billing practices of some therapist are doing.  Maybe if things were shakened up, we would see a change for the positive for the pt's we serve.  

Laurie June 9, 2008 10:08 PM
PA

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