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Following Correct Billing Guidelines; Co-Treatments

Vol. 17 •Issue 4 • Page 83
Medicare Advisor

Following Correct Billing Guidelines; Co-Treatments

Question: Our department received information that in June 2005, Medicare guidelines changed and PTAs and OTAs are limited in treating Medicare B patient to having direct supervision by a therapist, and cannot bill for this service. Do you have any information with regard to this?

Answer: The regulation you are referring to is in relation to assistants working under therapists in private practice. The regulation changed the level of supervision from personal (meaning the supervising therapist had to be in the same room) to direct (meaning the supervising therapist has to be in the building). The regulation for all other sites of service remains as it always has been: general supervision with periodic observation.

Question: I have a disagreement with my staff about how to bill for a co-treatment (i.e., PT/OT working with the same client at the same time). My understanding is that as long as each professional is providing his own skilled level of intervention and working toward the goals established in the plan of care, then each should bill for their time involved in that patient's care. The staff feels that if they are co-treating, only one of them should bill.

Answer: Kudos to your staff! Medicare is very clear on co-treatments for both Part A and Part B services. In both circumstances the total time spent with the patient can be either divided between the two disciplines ,or one discipline takes the total time. In either case, Medicare will only pay for the time the patient is receiving skilled services, not the time of the therapist.

Regulations about co-treatment for Part A can be found in the RAI manual under the explanation for how to complete Section P1b of the MDS. For Part B regulations, go to under team therapy.

Question: Please further explain your response in a previous column about PT in an outpatient clinic. Is the problem that the OT follows up the PT, then bills under the PT license number, or is the problem the aide turning on an infrared lamp, whirlpool, heating pad or dipping a hand in paraffin?

Answer: Both. First, one discipline cannot provide treatment under plan of treatment developed by another discipline. This is against all types of regulations, including Medicare and state practice acts. This practice is fraud if care is billed to Medicare or Medicaid.

The next problem is not with a non-professional providing the supervised modalities (i.e., paraffin, hot packs) under the supervision of a therapist. The problem is that they cannot provide constant attendance modalities such as ultrasound or therapeutic procedures such as exercises, and bill Medicare.

Question: Can a student physical therapist assistant treat Medicare patients in outpatient setting? What are the guidelines for students whether a SPTA or SPT?

Answer: The guidelines for use of students can be found in CMS Manual Pub. 100-04, Medicare Claims processing. In ¤100.10.1 Ð Therapy Students: it states "Only the services of the therapist can be billed and paid under Medicare Part B."

It goes on to provide examples, one of which is "Therapists may bill and be paid for the provision of services in the following scenarios. The qualified practitioner is present in the room guiding the student in services delivery when the therapy student and therapist assistant student are participating in the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time."

The manual can be accessed through the CMS Website at

If you have a question about Medicare reimbursement you would like the authors to address, send your question and contact information to Medicare Advisor, c/o Lisa Lombardo, ADVANCE for PTs & PTAs, 2900 Horizon Dr., King of Prussia, PA 19406; fax 610-278-1425;

Pauline Franko is owner and principal lecturer for Encompass Consulting & Education, LLC, a rehabilitation consulting and education company producing the "Medicare Made Easy" Series, (see our ad in ADVANCE); Danna Mullins is an associate and lecturer. You may contact the authors through their Website at


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