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Following the Rules for Group Therapy Billing

Vol. 13 •Issue 22 • Page 47
Medicare Advisor

Following the Rules for Group Therapy Billing

Question: Our rehab director recently read an article regarding developm.ents about group charges. The article states there is a new CMS directive, effective July 1, 2002, regarding when to charge for group versus individual treatment.

The article goes on to state that this directive changes the way Med.icare reimburses when a single therapist treats more than one patient at a time. It says providers must now bill as group therapy any time one therapist is treating more than one patient, regardless of whether the patients are performing the same or different activities.

Our director is concerned that we are not following this "new" rule. I thought this has always been the rule (maybe not always but at least the rule for the last several years). We have been following these guidelines since I became the supervisor of the outpatient clinics. We are confused about why this article is calling this regulation "new."

My question is, are there new regulations regarding when to charge group versus individual therapy?

Answer: You make an interesting point. Medicare has always said that what they pay for is direct one-on-one patient care (delivered by a therapist or therapist assistant), group therapy and modalities. Unfortunately, there are those organizations and therapists that don't follow this "one-on-one" rule.

In May 2001, CMS brought up concurrent therapy as a concern, because it didn't want companies dictating that a therapist treat more than one patient at a time.

The national professional organizations and others persuaded CMS that "concurrent therapy" was the same thing as "dovetailing," so Medicare didn't pursue it further at the time. The Medicare Advisors happen to disagree, knowing full well that some therapists treat many patients at the same time without charging for group therapy, and that this practice has nothing to do with dovetailing.

The "new regulation" that you are referring to probably comes from a transmittal from CMS to carriers clarifying group therapy charges under Part B. It really isn't a "new" regulation, it is simply a clarification for medical review. Transmittal 1753 dated May 17, 2002, states: "Pay for outpatient physical therapy services (which includes outpatient speech-language pathology services) and outpatient occupational therapy services provided simultaneously to two or more individuals by a practitioner as group therapy services. The individuals can be, but need not be, performing the same activity. The physician or therapist involved in group therapy services must be in constant attendance, but one-on-one patient contact is not required."

We believe that this transmittal says, in black and white, that anything other than one-on-one care (except supervised modalities) is group therapy.

You can access the transmittal through the CMS Website at and read it for yourself.


• Department of Health and Human Services. (2002). Medicare program, prospective payment system and consolidated billing for skilled nursing facilities-update; proposed rule. Federal Register, 66(91), 23991-23992.

• Department of Health and Human Services. (2002). Analysis and responses to public comment. Federal Register, 66(147), 39567.

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 Linda Jones, ADVANCE for PTs & PTAs, 2900 Horizon Dr., King of Prussia, PA 19406; fax (610) 278-1425;

Pauline Watts and Danna Mullins are the co-founders of Encompass Education Inc., a rehabilitation education and consulting firm in Palm Harbor, FL. You may contact the authors at


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