CMS released a national provider Comparative Billing Report (CBR) regarding private practice physical therapists who practice in the outpatient setting and bill Medicare with modifier KX (for therapy beyond the cap). This CBR is similar to the original study distributed last summer except this current study focuses on 2010 billing data and is being sent to 5000 additional or different providers, than the original 5000 that received CRB last summer.
The reports are sent to individual providers, rather than to the therapy group practice. This type of report is to be informational to the provider and individual results will not be aggregated for publication. Rehab agency, CORF, or hospital outpatient department therapy staff are not included in this study, only those therapists billing in a private practice either independently or through a PT/OT group practice. According to CMS:
The purpose of this Comparative Billing Report (CBR) is to help prevent improper payments by educating physical therapy providers using billing data for selected therapy services billed to Medicare. The CBR provides comparative billing data on how individual health care providers compare to their peers by looking at utilization patterns for billed services. The Office of Inspector General (OIG) released a report in December 2010 on Questionable Billing for Medicare Outpatient Therapy Services. The OIG has indicated that outpatient therapy expenditures have increased by 133 percent over the past 10 years which represents an increase of $2.8 billion. The OIG report also indicated that the KX modifier was over-utilized and exceeded annual therapy caps at levels much higher than the national average.
CMS has contracted with Safeguard Services (SGS) to provide comparative billing reports, and this report is the 8th in a series of reports release over the past year, and represents the 2nd report of physical therapists in private practice. The initial CBR was on physical therapists in private practice and was followed by reports on chiropractors, ambulance services, hospice, podiatry, sleep studies and DME/spinal orthotics.
A sample letter that was received by the 5000 physical therapists is provided at the CBR website. Of note, the CMS contractor for comparative billing reports is Safeguard Services (SGS) who also holds a contract with CMS as the Zone 7 Program Integrity Contractor (ZPIC). The Zone 7 Zpic has been active in Florida this summer with investigations of Comprehensive Outpatient Rehabilitation Facilities.