Medicare ADVISOR Q&A

Recertification Period Still Calendar-Based?; Concurrent Therapy Rules for Hospital Rehab Setting

Question: Medicare Advisor "Clarifying the 90-day recertification rules" (Vol. 19, Issue 13, page 47 of ADVANCE) states that "CMS has essentially eliminated the old certification period method of 'from date to date' and replaced it with a new certification period that is the 'time projected in the plan' and is no longer calendar-day based." My boss in the outpatient clinic disputes this and says otherwise, showing me a copy of a Medicare Manual which states that the recertification period is still calendar based, that is from date to date.

Will you be able to send me a copy of the Medicare Regulation which actually provides that the certification period of "from date to date" has been eliminated by CMS?

Answer: We love this kind of question! There is nowhere in the Medicare manual where it says there is no longer a calendar based certification period. But, what it does say in IOM Pub.100-02 Chapter 15, §220.1.3 Certification and Recertification of Need for treatment and Therapy Plans of Care, subsection B. Initial Certification of Plan is, "The physician's/NPP certification of the plan (with or without an order) satisfies all of the certification requirements noted above in §220.1 for the duration of the plan of care or 90 days from the date of the initial treatment, whichever is less."

In Transmittal 88, within CMS' instruction to the contractors §II. Business Requirements Table which defines the guidelines the contractors MUST work under, and which "shall" indicate a mandatory requirement, Number 5921.11 "Contractors shall interpret the certification interval as the longest duration described in the plan." It continues in §IV. Supporting Information, X-Ref Requirement number 5921.00 "There is no restriction on the way the duration of treatment or certification interval may be expressed. Variations may include e.g. calendar days, number of treatments sessions, or number of weeks of treatment. Contractors shall interpret the certification interval using the longest duration of the plan."

The instructions then continue "For example, if a plan is written and certified for 3x/week x 4 weeks and the patient receives treatment 3/xweek for 3 weeks but is absent the 4th week, then the planned 4th week of treatment is still certified if it is delivered later, assuming the plan remains appropriate and the treatment remains skilled and necessary."

The problem is that therapists have never let go of the 700/701 forms which CMS deleted from their manuals in 2003! These forms are no longer relevant to the information required for Medical Review purposes. Unfortunately, not only did therapists not accept this deletion, many software developers/manufacturers of documentation programs did not either, continuing to foster the acceptance that the 700/701 format was the only method of conveying Medicare requirements through documentation.

Question: Do the same rules apply for concurrent therapy in a hospital rehab setting as in a SNF?

Answer: Unfortunately, there are NO rules for hospital based Part A therapy with regards to concurrent therapy, co-treatments, use of aides or use of groups.

Pauline M. Franko, PT is owner of Encompass Consulting & Education, LLC; a consulting and education company specializing in Medicare Consulting, Compliance and Training, based in Tamarac, FL. The company's "Direction on Demand" service specializes in providing the rehabilitation professional with a clear, easy way to understand how to provide Medicare compliant services to their patients in the SNF and Outpatient settings. As an associate in Comprehensive Medicare Consultants, LLC, she is responsible for assisting with and directing compliance programs to Rehab Agencies. Danna Mullins is an associate and lecturer with Encompass. You may contact the authors through the Encompass website at or by phone at 954-720-4087.

Medicare Advisor Archives

Can I have clarification with the frequency and duration of therapy. With X Ref Requirment Number 5921.00, as an example an order of PT 5x/wk but pt was only seen 4x the first week can the pt be seen 6x the following week to "catch up" or comply with the order?

Lee May 23, 2015

Do recerts have to be done in 90 days or every 10 visits? Pat Zachmann said we didn't need to be concerned with number of days, but that we needed to recert every 10 visits. She stated this during a CMS course in September 2014.

Patricia Thibodeau,  PT/Dir. Rhab Services,  MRHNovember 25, 2014
Millinocket, ME

Where can I find information on Maintenance Program for patients with Neurological Diagnoses in Home Care
setting? What other requirements needed to allow this program in home haealth aside from being homebound. What are the limitations associated with this program? Please advise. Thank you. Cris

Cris November 17, 2008


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