Physical therapy in the Office of Inspector General (OIG) 2015 Work Plan should be no surprise. Physical therapists in private practice have been in the cross hairs in the OIG’s annual Work Plan for the past four years. The OIG has issued several reports under Office of Audit Services #W-00-11-33220 including Spectrum Rehabilitation, LLC, Claimed Unallowable Medicare Part B Reimbursement for Outpatient Therapy Services and An Illinois Physical Therapist Claimed Unallowable Medicare Part B Reimbursement for Outpatient Therapy Services. Further reviews are underway by the Office of Audit Services of physical therapists in private practice.
For 2015 the work plan for physical therapy is stated as follows:
We will review outpatient physical therapy services provided by independent therapists to determine whether they were in compliance with Medicare reimbursement regulations. Prior OIG work found that claims for therapy services provided by independent physical therapists were not reasonable or were not properly documented or that the therapy services were not medically necessary. Our focus is on independent therapists who have a high utilization rate for outpatient physical therapy services. Medicare will not pay for items or services that are not “reasonable and necessary.” (Social Security Act, § 1862(a)(1)(A).) Documentation requirements for therapy services are in CMS’s Medicare Benefit Policy Manual, Pub Pub. No. 100-02, ch. 15, § 220.3. (OAS; W-00-11-35220; W-00-12-35220; W-00-13-35220; W-00-14-35220; W-00-15-35220; various reviews; expected issue date: FY 2015)
Physical Therapy OIG 2015 Work Plan: Lessons for All Therapy Providers
While the provider selection for outpatient therapy review is limited to physical therapists in private practice there are lesson for all therapy providers, including occupational therapists and speech-language pathologists in private practice. The findings related to the above references cases have to do essentially with compliance with Medicare regulations and documentation requirements for all outpatient therapy, not just physical therapists in private practice. To that end the lessons learned should be applied to risk assessments, as well as auditing and monitoring activities for all outpatient therapy providers including hospitals, rehab agencies, CORFs and skilled nursing (Part B).
Have you reviewed the OIG Work Plan? Have you studied the OIG reports on therapy mentioned above? Have you assessed your facility or department’s risk against the OIG findings?