The question of therapy groups always seems to come up for therapy providers after a staff member has attended a CEU course, or perhaps sought out advice via an online message board or list serve. Invariably the information is not accurate. It’s happened again! Let me call it the rogue weekend CEU course as the culprit. So what is a therapy group? When is a therapy group a therapy group, and when is it not? How many people can be in a group, do they need to be doing the same thing? Can an assistant run a group, can a tech run a group? Is a group the same as concurrent therapy? What is the difference between a group of patients in an outpatient setting, a SNF or an IRF?
Therapy Groups Defined
Outpatient Therapy – Therapy Groups
For outpatient therapy providers billing the Medicare Part B program for outpatient therapy, Medicare will pay for outpatient physical therapy services provided simultaneously to two or more individuals by a “practitioner” as group therapy services using CPT© 97150. The individuals in the group can be, but need not be performing the same activity. The therapist involved in group therapy services must be in constant attendance, but one-on-one patient contact is not required. (Medicare Benefits Policy Manual, Chapter 15, Section 230 (A). A warning to outpatient therapy providers using the group code: check your Medicare Administrative Contractor’s (MAC) local coverage determination (LCD) for guidance on the use of the code and specialized documentation that may be needed as evidence to support the use of the code. Keep in mind that the group therapy code is purposeful, it is not a code to be utilized just because therapy visits of two patients inadvertently overlapped.
Skilled Nursing Facility – Therapy Groups
In the skilled sub-acute SNF setting there is a differentiation between individual therapy, concurrent therapy and group therapy. (That has absolutely nothing to do with outpatient group therapy!) Concurrent therapy is one therapist treating two patients, however, both patients are performing separate treatments that are unrelated. For example one patient performing a progression of lower extremity therapeutic exercises, while the other patient is performing therapeutic activities involving reaching overhead to place items on a shelf. The therapist’s attention is divided between the two patients. Per the RAI Manual “Group therapy is defined for Part A as the treatment of 4 residents, regardless of payer source, who are performing the same or similar activities, and are supervised by a therapist or an assistant who is not supervising any other individuals”. So it looks like the folks in our photo are over the group limit!
Inpatient Rehab Facility (IRF) – Therapy Groups
CMS has always indicated the expectation that patients in an inpatient rehab facility will receive the majority of their minimum 3 hours of required daily therapy as individual treatment. There are no specific rules at this time, but CMS has fired a warning shot across the bow of the collective IRFs indicating they feel a “group creep” is in place. The IRF FY 2010 PPS final rule indicated that the standard of care for IRF patients is individualized therapy.
Do you understand the definition of group for your setting? Do you know how to document group appropriately? Do you work in a SNF where you treat both Part A (PPS) and Part B (outpatients)?