CMS suspended most audit activity this spring as a result of the Public Health Emergency (PHE). As the summer comes to an end, yet the PHE continues, CMS is signaling that it is getting back to the business of medical review. As Palmetto GBA has announced the return of post-payment audit reviews, other Medicare Administrative Contractors (MACs) have done so via their websitesor list serves. Physical Therapists in Florida are reporting audit notifications for As Palmetto GBA has announced the return of post-payment audit reviews, other MACs have done so via their website or listserves. CPT® 97110 (Therapeutic Exercise).
The Florida MAC is First Coast Services Options or “First Coast”. Given the Medicare population in Florida, and their extensive audit experience with therapy providers, if you are in Florida, be prepared for detailed medical necessity review. The “Service Specific Review” topic announced is Rehabilitation Services: Outpatient Physical and Occupational Therapy (CPT 97010-97546) with an August 2020 beginning date.
According to First Coast
First Coast performs data analysis on a regular basis on all services billed to Medicare to identify services that are frequently not billed and coded correctly per Medicare guidelines. Post-pay service-specific reviews are performed based on results of a widespread data analysis that focuses on specific topics. If you bill Medicare for these services, you may receive an additional development request (ADR) letter asking for documentation. This allows First Coast to validate that you have billed the services correctly according to Medicare guidelines. Once the ADR is received, you will have 45 days to respond to the request with the supporting medical record documentation. The review will be completed within 60 days of receipt of the documentation. When the review is completed, you will be notified of the results.
Has your MAC announced the resumption of therapy audits? Have you received an ADR letter from your MAC identifying your practice or individual therapists for post-payment review? Are you prepared for a Medicare audit? Let us know if we can help – this is our expertise.
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