The Comprehensive Error Rate Testing (CERT) Program continues to highlight errors in physical therapy billing as evidenced by the 2nd Quarter Report posted by Wisconsin Physician Services (WPS), the Legacy Part B provider in MInnesota, Illinois, Wisconsin and Michigan. The most recent reports continues to highlight the fact that therapy minutes (as documented in the medical record) do not support the codes and services that were billed. Of the 46% payment error rate for insufficient document therapy is among the top reason stated for the high error rate.
The CERT program is designed to measure the error rate of the CMS contractors, and as such the various contractors pay close attention to the quarterly report card, and continue to advise providers what they must do to correct the errors. Additionally the CERT program is being utilized by other CMS Program Integrity Contractors, including the Recovery Audit Contractors (RAC), Program Safeguard Contractors as well as the Zone Program Integrity Contractors (ZPIC) to identify vulnerabilities and topics for review under their respective statement of work.
For therapy providers it pays to develop a system of checks and balances through your compliance auditing and monitoring program to ensure on a daily basis that all codes billed are supported by not only documentation of medical necessity, but clear documenation of the minutes as required by Medicare documentation rules for Part B therapy as stated in the Medicare Benefits Policy Manual, Chapter 15, beginning at Section 220.