Effective April 9, all physical, occupational, and speech therapy orders will be available through a new outline called Rehabilitation Services. Within the outline, physicians will be directed to the correct therapy order based on whether the patient is an inpatient, observation patient, or if therapy should start post hospital discharge. This change will improve care coordination with therapy services and also support our system of care model.
When therapy services are provided to a patient while in observation, the patient is billed as an outpatient. Prior to October 1, 2012, therapy services performed in a hospital-based system were exempt from certain reimbursement restrictions. The hospital systems are no longer exempt and these restrictions have been extended to the end of December 2013.
Therapy services billed under the patient's Medicare Part B benefit is applied to the patient's overall benefit "cap." This cap includes $1,900 for physical therapy and speech therapy combined, and $1,900 for occupational therapy. The annual maximum benefit for physical and speech therapy combined, and for occupational therapy services is $3,700. This is a cumulative benefit, and use of this benefit is applied to all settings and diagnoses throughout the calendar year. Once the patient reaches the $3,700 limit, the medical record will be audited by the RACs. For observation patients, this audit will include the entire medical record, as therapy documentation and charges are integrated into the patient's single account. When the patient is in the hospital or in observation, they are not aware that their benefit is being used while they receive therapy in this setting.
In order to support the patient and healthcare team, while also giving consideration to the regulation and reimbursement restrictions now in place, therapy evaluations may be completed while a patient is in observation, however further treatment will be recommended for the next most appropriate setting. It must also be noted that charges for therapy services can average $300 a visit, and that use of the benefit in the hospital under observation will limit/restrict the patient from receiving services in the post-acute setting.
For questions or additional information, please contact Karen McCauley, Director of Physical Rehabilitation Services, at extension or pager 3560.