Question: Just a quick question regarding something about which I am a bit confused. Does Medicare require a 700 form for PT initial evaluation, or can we use a form that reads "PT Evaluation and POC"? Everyone I ask has a different answer.  Can we continue to use the 700?  Is it a requirement from Medicare?

Answer: First of all, CMS totally eliminated the 700 and 701 forms from their website in July 2003. Further, they indicated that the provider could use any type of documentation it preferred as long as it contained the information required by Medicare to meet the Medical Review requirements.

In order to determine if continued use of the 700 form is even appropriate, one needs to understand exactly what the purpose of the 700 and 701 forms were/are. The purpose of the forms was to act as the Plan of Treatment for Part B Outpatient services. The form included certification and re-certification of patient need for the services, the physician signature verifying approval of the plan, and the initial document for Medical Review. The 700 form contained the summary of the initial evaluation while the 701 form contained the 30 day progress report for the physician indicating the progress the patient had made in that period.

The bottom sections of both the 700 and 701 were only to be completed if the provider was requested to provide information pertaining to Medical Review for necessity of treatment. In this section, the provider indicated the progress that the patient had made during the period under review (always a calendar month.) If the 700 covered part of that calendar month and the 701 covered the remainder of the month, the provider would indicate the progress made during that timeframe on the 700, along with the identification that services were continued. Then the 701 contained the progress made up to the last date of the review. These forms were sent as requested and the reviewer determined if the documentation supported payment. If not, then there was a further request for the actual documentation of evaluation and treatment notes.

When the method of Medical Review and the depth of information required changed, this form was no longer adequate. Medicare indicated that providers could develop their own method of documentation to support the POT and certification requirements.

So, after that roundabout answer, we want you to know that you can create your own documentation for evaluation and plan of treatment. We also want to remind you that Medicare has stated that, although it requires an evaluation and plan of treatment, these can be contained in a single document or documented separately. The only requirement is that the plan be sent to the physician for review and approval.

Medicare no longer requires that a progress report be sent to the physician. Updating the plan is only necessary if the initial certification interval is exceeded due to the patient not meeting the long term goals in that interval. When that happens, an updated plan has to be sent for recertification by the physician.

Disclaimer: The answers that we provide are based on Medicare guidelines for what is payable under the Medicare Part A and Part B Benefit. As always, the provider should be aware of the other regulations that might supersede the Medicare payment guidelines such as the State Practice Act and the State Administrative Code. In any scenario, the practitioner must go with the most stringent requirement in order to be compliant. The information provided is current as of the time of publication.

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. Danna Mullins is an associate and lecturer with Encompass. You may contact the authors through the Encompass website at www.encompassmedicare.com or by phone at 954-720-4087.