Outpatient Therapy: Myths and Risks
Outpatient therapy, particularly physical therapy, continues to be an area of concern for providers, regulators, investigators, adjudicators, and legislators. With Centers for Medicare & Medicaid Services (CMS) having entered an enlightened era of reducing provider burden, outpatient therapy providers are not necessarily “feeling the love,” more~
Dry Needling Codes: Compliance Implications
Physical therapists performing dry needling in their practice in prior years often “reported,” debated, or perhaps argued, a number of different methodologies to justify coding and billing. Some providers billed for an unlisted procedure, or unlisted modality, likely guaranteeing that a denial was forthcoming. Other providers justified the use of another CPT® code, such as manual therapy, or neuromuscular reeducation, despite dry needling not being identified as part of those codes.
I Know Who You Are and I Saw What You Did: Social Media, Your Practice, Ethics & Laws
Who isn’t on social media? Therapists on social media platforms such as Facebook, Twitter, LinkedIn, and Instagram are in good company. Have you “connected” with the Office of the Inspector General (OIG), the United States Department of Justice (DOJ), CMS, your Medicare Administrative Contractor, your representatives in Congress, the APTA? It seems everyone is on social media, so all must be okay, correct? more~
The Intersection of Civil Rights and the End-of-Life-Care
Enforcement actions, Centers for Medicare & Medicaid Services memorandums, Office of Inspector General reports, and survey and certification guidance have given providers multiple touch points to update their compliance risk assessment, develop additional compliance monitors, and determine opportunities for specialty audits. The U.S. Department of Health & Human Services’ Office for Civil Rights (OCR) issued guidance early on in the public health emergency, easing enforcement actions while..more~
Comfortable Comfort in Compliance
This year may be best described as “the year of living dangerously,” as we get ready to end the summer and look forward to a Labor Day weekend that signals the march to the end of the year. The disruption caused by the new skilled nursing facilities’ Patient-Driven Payment Model and the new home health Patient-Driven Grouping Model gave way to COVID-19 and helped declare a pandemic and a public health emergency more~
COVID-19 and Compliance: Resources Hiding in Plain Sight
Compliance challenges as a result of the COVID-19 pandemic have likely sent therapy practices scrambling for information, only to find information — and misinformation — often a moving and changing target. Practices have addressed, and are likely still addressing, clinical, operational, and financial challenges. Compliance obligations under HIPAA, Medicare Conditions of Participation, and Section 1557 of the Affordable Care Act have come … more~
Taking the Bridge Over Troubled Waters
Is it June already? Already we have been through an incredible rolling healthcare crisis that will likely continue to ripple through the summer, into the fall, and as it snows here in Wisconsin. Hospitals, nursing facilities, rehabilitation facilities, and those providing home health and hospice in post-acute care alike have experienced the testing of their infection control policies and procedures, as well as … more~
The Best of Times, the Worst of Times: Compliance Opportunities
“It was the best of times, it was the worst of times, it was the age of wisdom, it was the age of foolishness, it was the epoch of belief, it was the epoch of incredulity, it was the season of Light, it was the season of Darkness, it was the spring of hope, it was the winter of despair…. more~
Disruptive Changes Bring Compliance Opportunities
Have you heard the phrase, “Everything old is new again”? It seems odd in today’s technology and communication. Imagine the time when the mail was delivered by Pony Express. A message would take more than a week to travel cross-country. Fast-forward to the invention of the telegraph in the mid-nineteenth century and rapid development of telegraph companies that sent “cables.” Coded expressions. more~
Instagram STOP What is Old is New Again STOP
Have you heard the phrase, “Everything old is new again”? It seems odd in today’s technology and communication. Imagine the time when the mail was delivered by Pony Express. A message would take more than a week to travel cross-country. Fast-forward to the invention of the telegraph in the mid-nineteenth century and rapid development of telegraph companies that sent “cables.” Coded expressions. more~
Heading into the last several months of the year, the last of the leaves are falling, the sun is lower in the sky, witches and goblins appear as lawn decorations getting ready for Halloween, Christmas ornaments are on display, retail stores are closing physical locations as online stores take over, and it seems that Amazon has achieved super store status beyond the definition of super store. more~
Disconnecting: What’s Your Plan
Some may recall the Ben Casey television series of the early Sixties. The show started with Dr. Zorba uttering “man..woman..birth..death..infinity..” as the symbols for each slowly appeared on a chalkboard during the opening credits. Infinity, with the side-lying number eight, has a new meaning today in the age of connectivity, causing all to consider: Once connect is there a path to disconnecting? more~
Connecting: Achieving A Mental State
First start by selecting a mental state you’d like to achieve. Do you need to focus? Certainly, this is an occupational necessity for compliance professionals. Do you need to relax? Compliance professionals would likely benefit from a brief relaxation time-out every day. Do you need to meditate, take a nap, or sleep? What about the need to recharge? This is where Brain.fm may provide opportunities for all the above. It’s described as the “most advanced AI music composer on the planet.” more~
FEMA: The Must Have Emergency App
As the year comes to an end, it is likely that your region of the country, whether it’s Hawaii, Maine, Florida, California, or parts in between, experienced some type of disaster or emergency. Whether it was an active erupting volcano, a tornado, raging wildfires, mudslides, a hurricane, or an act of violence, it likely impacted your healthcare facility and its services, as well as your community at large. FEMA plays more~
Voice Controlled Digital Gadgets: The Fly on the Wall That Tells
Have you ever asked your personal digital assistant on your smartphone to look up something for you? Certain commands and words trigger a sequence. On an iPhone you can click and start your question by asking, for example, “Siri, can you find the nearest Oktoberfest?” In the past few years, we have experienced a boom of virtual devices that do everything: more~
It all started when I learned to type on my mom’s vintage Royal typewriter. It got more exciting when I went to my dad’s office in high school to use his shiny new IBM Selectric with the Courier 12 type ball. Soon there were huge word processing machines, followed by the introductory computers — mine was an Apple IIc. I took typing between summers in high school, where I learned the basics: more~
Connecting for Advice, and Maybe a Breach? Facebook Grand Rounds
It all started with grand rounds – my questions and answers about therapy patients. Let me give you some context. I started my career in therapy at the most exciting time. I was developing wheelchair sports programs, community integration rehabilitation activities for discharged spinal cord-injured patients, and often spent the day in my rehabilitation center’s therapy pool. During those days over 30 years ago, I learned compliance from all the risk management exposure more~
Put It In Your Pocket, Save It For A Rainy Day
In the “old” days, clippings from newspapers, magazines, and brochures joined cards and pictures that were stored safely in desk drawers, file cabinets, and bedside tables, all ready for when there was time to read, be inspired, or simply to look back and reflect. In the inevitable New Year’s “tidy up” resolutions earlier this year, I worked through the collection. A professional organizer would be proud. more~
Paging…Paging…What’s Old is New!
It sort of started when several providers were looking for secure and encrypted texting solutions to communicate messages about patients throughout the treatment day. Then another provider was instructed by a referring physician group that they would be communicating with
providers by texts rather than emails or faxes, so they needed a recommendation on a secure texting solution. Texting options have been discussed on HCCAnet — a great place to get feedback more~
A Picture Says a Thousand Words – Be Careful What You Say
A picture says a thousand words, or so they say. Pictures enhance social media posts, whether on Facebook, Twitter, Instagram, or for that matter, most social media platforms. New smartphones boast of high-end cameras and photo capabilities. A new “square” photo format is gaining popularity for its ability to be sized to take up more space in your post or tweet, and various studies suggest that pictures that accompany posts and tweets are more likely to be opened and shared. more~
Are you on Facebook? Even if you aren’t on Facebook, it is likely as a compliance professional that you have a policy on social media, and it may very well be centered around Facebook as the most popular and widely used social media platform. It has to be obvious that the Connectivity column hasn’t done much of a dive into Facebook. It seems that the time has come, because Facebook is too big to ignore
in 2017. more~
Rehab Under Review: The Devil is in the Details
The risk in outpatient therapy, including physical therapy and occupational therapy, seems to grow exponentially each year, but at the same time these services continue to suffer reimbursement hits from governmental programs, most notably Medicare, but commercial payers as well. Providers report concern over the lack of subject matter expertise by the various review entities and reviewers. Author’s note: this article provides insight into the manual medical review process chart reviews. more
A Picture Says a Thousand Words – Be Careful What You Say
A picture says a thousand words, or so they say. Pictures enhance social media posts, whether on Facebook, Twitter, Instagram, or for that matter, most social media platforms. New smartphones boast of high-end cameras and photo capabilities. A new “square” photo format is gaining popularity for its ability to be sized to take up more space in your post or tweet, and various studies suggest that pictures that accompany posts and tweets are more likely to be opened and shared. more~
Are you on Facebook? Even if you aren’t on Facebook, it is likely as a compliance professional that you have a policy on social media, and it may very well be centered around Facebook as the most popular and widely used social media platform. It has to be obvious that the Connectivity column hasn’t done much of a dive into Facebook. It seems that the time has come, because Facebook is too big to ignore in 2017. more~
Engaging On Twitter: It’s All About Style
Twitter has enhanced the experience over the years. Whether you engage with Twitter directly via your Twitter page, or via a social media platform such as TweetDeck or HootSuite, you can’t help but notice the engaging pictures, videos, and photos that are becoming routine with Tweets. In fact, you are more likely to engage with the Tweet by opening the link just because a picture enhanced your interest. Are you left wondering how you can add graphics and videos to your Tweets? more~
Are you still sorting through all the great information from the Compliance Institute, or perhaps overwhelmed that you may forget all the mentions of compliance references and resources? It’s not too late to curate information from Twitter, Instagram, Facebook, and web postings. In fact, even if you missed the Compliance Institute at National Harbor, you have an opportunity to curate the best of what happened. There is a Twitter tradition at the Compliance Institute (the official hashtag is #HCCAci), and each year the number of attendees tweeting increases, perhaps encouraged by seeing their tweets scroll on the live screens located throughout the event. more~
It all started with a call from a trusted compliance colleague, a healthcare attorney certified in healthcare compliance and, in my impression, a pretty cool, calm, and collected advisor. Imagine my surprise when this trusted colleague admitted that he looked to the Apple Store for an app that would help him relax. Wow—if he needed an app to find help in relaxing, maybe the rest of us could use an app to relax and release some compliance officer stress. Here in Wisconsin, “R-E-L-A-X” as a meme became famous when Green Bay Packer’s #12 Aaron Rodgers signaled to fans that he had it covered on his ESPN Milwaukee radio show: “Five letters here just for everybody out there in Packer-land: R-E-L-A-X. Relax. We’re going to be OK.” more~
Love, Honey Do, and Wunderlist
This all started when compliance colleague, Laura, CHC, was telling me one day that she discovered a fun new app – one that allowed her to discreetly create “Honey Do” lists for herself and her husband. Hmmmm, success with creating a husband’s To Do list? A marriage made in heaven! I am sure she relished the opportunity and enjoyed the satisfaction of having the app do something that would never be possible. Leaving a list on the kitchen counter just hadn’t always ended up with the intended result. Laura related that they appreciated the collaboration, communication, and follow through of the app. They were getting things done and checking things off the list in a different way than ever before. I’m listening and thinking, “I need to get this app,” as you can guess, slipping in some “Honey Do” items appealed…more~
How Can My Practice Become Compliant?
What does it mean to be compliant? That was one of the questions posed recently in an online email listserv. The clinic director/therapist posing the question wondered if clinic staff should reread their compliance plan (purchased), take some sort of a quiz, or listen to yet another training program. Truth be told, compliance is not that simple, but neither is it too complex for the small therapy practice to scale a compliance program. more~
Coloring therapy for compliance officers is now available on your mobile devices. Unlock your inner compliance self and reduce your job stress. After all, it was at the 2012 Compliance Institute where we learned that compliance officers were stressed! Hardly a secret, even OIG Dan Levinson addressed it in his keynote that year. Coloring for adults is all the rage this year. Front tables of the local bookstore are covered with adult coloring books to suit a variety of interests. more~
As we hit the final stretch of the fall Presidential campaign, your social media feeds are likely jammed with paid political ads or clutter from the feeds of your “friends,” your phone is ringing off the hook with robo calls, and you are wondering, “How can I get through the next 30 days with a bit of peace?” Even if the ads are for your candidate or your party, at some point you may want to tune in to a favorite movie, but which movie will you pick? There is an app for that! more~
Hiding in Plain Sight – Therapy Coding Billing and Compliance Risk
It all started out with a call from a health law attorney. He represented a small private practice that was under investigation. The therapy practice was in receipt of a civil investigative demand (CID); the U.S. Attorney’s office was involved as well as investigators representing federal health care programs. Is therapeutic exercise a one-on-one code? mused the attorney. If it is, how can a small practice stay in business if they have to treat patients individually? was the follow-up question. more~
Have you joined the HCCA compliance community? While you likely have social media apps on your smartphones and tablets to keep in touch with compliance colleagues via Twitter, Facebook, or Pinterest, you may be missing the best kept secret in compliance success — HCCAnet. more~
Goodwill Hunting – Mergers and Acquisitions Compliance
The mergers and acquisitions frenzy: It is likely to hit your market, or about to hit your market. At the Private Practice Section (PPS) annual meeting 18 months ago, two major market acquisitions were announced, which lit up conversations in the exhibit hall for the duration of the conference. Practice owners are accustomed to looking at exit strategies or succession plans unique to their practice; however, now practice owners have to take notice of major therapy companies migrating around the country and immersing themselves into new, untapped markets as well as penetrating deeper into existing markets. more~
Oh, somewhere in this favoured land the sun is shining bright, The band is playing somewhere, and somewhere hearts are light; And somewhere men are laughing, and somewhere children shout, But there is no joy in Mudville — mighty Casey has struck out.
— Ernest Lawrence Thayer “Casey at the Bat
Who doesn’t like sports? Whether you are in the office pool for the Super Bowl, filling brackets for the Final Four, playing in a fantasy league, or just enjoy Kevin Costner baseball movies (Kevin Costner football movies, Kevin Costner golf movies, or any Kevin Costner movie), sports surround us. We talk sports at the watercooler; use sports language to describe business (and perhaps compliance) strategy; and wear sports watches, sports shoes, and sport shirts — even if we don’t play sports. more~
#HCCAci — What Happens in Vegas, Stays in Vegas! (Whoops! Except your Tweets!)
It’s another year, another HCCA Compliance Institute, and another TweetUp! It is no secret that the social media platform of choice at the CI is Twitter (#HCCAci ), but this year, there is an opportunity to try some different social media apps in addition to tweeting all the live action. more~
In A Snap! Now You See It, Now You Don’t!
Once again in the digital era and Web 2.0, what’s old is new and what’s new is old. Or at least the concept behind the Snapchat app seems to suggest it is. more~
The compliance landscape for outpatient therapy looks remarkably different entering 2016 than it has for the past few years. For a lot of practices an “out of sight, out of mind” attitude has gravitated to an “I cannot sleep at night” feeling. So what has happened over the past year? What are steps a private practice should take to mitigate compliance risks?. more~
Remember the old submarine movies when there would be a command to “up scope” and the captain (for example, Clark Gable in Run Silent, Run Deep) would take a peek at the activities on the surface? The Periscope app, recently made part of the Twitter platform, allows app users to “up their Periscope” and give their followers a view of the live action. more~
Pocket, Paper.li, and Juice: Creating Your Own Digital News Service
USA Today is often thought of as the first news “aggregator”. Reading the USA Today paper edition while traveling has always been a luxury. With a digital subscription on my tablet, reading the paper is a daily activity. Now users of social media can be their own aggregators of information, and share it with their networks. Pocket, Paper.li, and Juice are my favorites to use. All serve a similar purpose of aggregating information, but in different and unique ways. more-
iTuning with Podcasts: Movin’ and Groovin’ to Compliance
iTunes is not just for music. Remember the introduction of the portable pocket media player nearly 15 years ago? Now in addition to rocking while doing your morning workout, you can watch high-definition movies and listen to podcasts. In fact, you don’t have to be exercising to do so. Catch the latest by logging in to iTunes on your iPhone, iPad, MacBook, or PC. For those sporting the new Apple Watch, what could be easier than a flick of the wrist? more-
PQRS Opportunity: Last Chance to Stave off a Penalty Reduction in Reimbursement
This compliance topic is in response to requests by many private practice members to understand the Physician Quality Reporting System (PQRS) and to effectively report to stave off future payment reductions. The focus is on claims-based reporting. American Physical Therapy Association (APTA) members are encouraged to visit www.apta.org/PQRS for a wealth of information about the PQRS program including reporting requirements. more-
Remember your first camera? I had a Kodak Instamatic and thought I was in seventh heaven for capturing all the memories of my junior year aboard to Europe. Looking back, I’m not quite sure what was “instant” about the Instamatic. more-
The Centers for Medicare & Medicaid Services Recovery Audit Contractor Program
The Centers for Medicare & Medicaid Services (CMS) Recovery Audit program has been under way for more than 6 years. Following a demonstration program that ran from 2005 through 2008 in several states, the Recovery Audit Contractor (RAC) program was permanently implemented in the Tax Relief and Health more-
#HCCAci — It’s That Time Again, and Everyone Can Get Connected in the Tweet Fest!
We have all been waiting for this — a chance to meet and greet using social media at the 2015 Compliance Institute @Disney . The exciting part of social media is that everyone will be able to join in the excitement, even if you are not in attendance. The preferred social media platform at the CI is Twitter, because everyone can join in the communication stream live — you don’t have to be onsite! more-
February, and Love is in the Air: Time for Pinning with Pinterest
Remember the musical Bye Bye Birdie? Can you resist humming along with the lyrics: What’s the story, morning glory? What’s the word, hummingbird? Have you heard about Hugo & Kim? Did they really get pinned? Did she kiss him and cry? Did he pin the pin on? Or was he too shy? more-
Outpatient Therapy Claims: Medical Review and Audits
It is no secret that Medicare review of therapy records and claims have increased this past year. while largely due to the mandated manual medical review of therapy over the $3700 threshold by the Recovery Auditors, other initiative have resulting in therapy chart reviews. The Office of Inspector General (OIG) continues with audits of private practice physical therapists more-
Ever wonder what those little pixelated square black and white codes are? Ever wonder why people take pictures of them? Smartphones and tablets (and even “phablets”) are getting bigger and better, smart watches have been added to the mix, and there is an endless possibility for not only healthcare use, but compliance focus. more-
YouTubing Your Way to Compliance Training
Do you ever need to get a quick training module out to physicians or staff? Is this the type of training or message that doesn’t need a formal sign-in sheet, the expense of a buffet lunch, the scoring of a quiz, or even the formality of a learning management system? The recipe is as easy as assembling content in PowerPoint or Keynote, recording it with an audio/visual screen capture program such as Camtasia, producing it in a video format, and then publishing it to your YouTube channel. more-
Over the past several years, the escalating number of Medicare denials has resulted in a record number of appeals making their way to the 3rd Level Administrative Law Judge (ALJ). Appeals have skyrocketed in large part due to denials in the recovery audit program (RAC) and the successful resolutions providers are receiving at the ALJ level. The escalating number of cases reaching the Office of Medicare Hearing and Appeals (OMHA) has prompted Chief Judge Nancy Griswold to declare a temporary halt to the assignment of new cases to the various ALJ regions. more-
Jimmo v. Sebelius: The Myth of the Medicare Improvement Standard
The Settlement Agreement in the matter of Jimmo v. Sebelius was approved by the U.S. District Court for the District of Vermont. Beginning in December of 2013, CMS began a series of steps required under the settlement to inform and educate providers, suppliers, contractors, adjudicators, and beneficiaries regarding Medicare policy so that beneficiaries could receive the full coverage to which they are entitled. Of note to therapy providers are the revisions made to the Medicare Benefits Policy Manual (MBPM) for skilled nursing, home health, and outpatient therapy. More-
It seems like Twitter users never sleep. Are you tempted to take a peek at my Twitter feed in the middle of the night? It seems it’s during “off” times the most interesting tweets come through. Take Twitter user @Domotalk’s tweet: “Data Never Sleeps 2.0.” The tweet links to an infographic showing the amount of data generated every minute. The infographic notes, “With each click and share, and like, the world’s data pool is expanding faster than we can comprehend.” more–
Q: What is an insurance plan benefit design and what does it mean for therapy providers? A: An insurance benefit design specifies services that are covered under the health insurance plan, whether government-funded, employer-funded, or a personal plan (available to individuals and families via insurance brokers). The benefit design includes deductibles, various co-payments for physician and emergency room visits and hospital stays (including inpatient rehab and skilled nursing) as well as prescription drugs, laboratory, radiology, and additional benefits such as physical therapy. more-
Tweet me up! Getting social at the Compliance Institute
The Twitter hashtag for the Health Care Compliance Association Compliance Institute (#HCCAci ) couldn’t have been more social. Tweeting (sending message of ≤140 characters on a smartphone or tablet) got started prior to everyone’s arrival in San Diego. A new app (application for smartphones and tablets) was revealed: 1,380 downloads to iOS devices (829 on iPhone, 531 on iPad) and 246 to Android devices—learly compliance is Apple-oriented. (An apple a day keeps the OIG away?) more-
The world of outpatient therapy, including physical therapy, occupational therapy, and speech language pathology has seen risk grow exponentially over the past year, while at the same time suffering reimbursement hits from governmental programs, most notably Medicare, and commercial payers as well. more-
Compliance 101: Physical therapy, the referring physician and Stark regulations
Do Physicians have long referred their patients for physical therapy services to community and hospital-based physical therapy and rehab departments. Many physician practices, particularly those that have the propensity to refer large volumes of patients for physical therapy in particular, have developed therapy services and clinics within their practice. Following the enactment of Stark I, many physician groups divested their therapy practices amid concerns of non-compliance with the self-referral law.
The landscape of physician-owned physical therapy practices (POPTS) has been repopulated over the past decade as physician groups have taken advantage of the in-office ancillary exception available under the Stark II regulations. more-
Therapy provided “incident to”: Developing a framework for compliance by identifying risk
Do you provide physical or occupational therapy services incident to your practice? Are you considering adding these services? This article will provide your practice with a basic framework for understanding key elements of a voluntary compliance program with an emphasis on risk areas that have been identified by the OIG. Background: The Office of the Inspector General of the Department of Health & Human Services (OIG) issued the final version of its “Compliance Program for Individual and Small Group Practices” (Guidance) in October of 2000. The Guidance stressed the voluntary nature of a compliance program, but also highlighted the benefits that such a program can confer on physician practices, not only to do the right thing, but also to streamline business operations. more-
Nancy Beckley 