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Are you on the prowl for helpful outpatient rehab resources?

Rehab Regs, April 1, 2004

The information's out there-if you know where to look

Have you ever wished that all the manuals, forms, and regulations you need to do your job efficiently and effectively were right at your fingertips? They are, if you know how to navigate the Internet-a plethora of information awaits with just the click of your mouse. The tough part is navigating through all of the existing Web pages to find what you need.

If you're still surviving without daily Internet use, take a crash course to become Web savvy and save yourself time and frustration. "If you feel like the Internet is just an option, you couldn't be more wrong," says Ken Mailly, PT, of Mailly and Inglett Consulting, LLC, in Wayne, NJ. "If you don't have Internet access, then you're in a position where the public knows more about your business than you do."

Now that almost all facilities are Internet accessible, government sites make forms and manuals available not only for convenience, but also so you can't say you were unable to access the information. "The government is putting this information online so we can't say we didn't know," says Mailly. "It's a convenience, but there's also another wrinkle-it takes away the ignorance defense."

If you want to stay on top of industry changes and make your rehab facility run smoother, you should be familiar with the resources available from the following places:

If you bill Medicare, check the CMS Web site weekly, says Rick Gawenda, PT, director of rehab services at Detroit Receiving Hospital in Michigan. "Any changes from CMS will be on the Web site," Gawenda says. "If you deal with Medicare and you're responsible for reimbursement, you need to know where and how to find this stuff."

Gawenda suggests you look at www.cms.hhs.gov/manuals to become familiar with the CMS site. From here, you can scroll to "paper-based manuals," which will take you to a list of CMS manuals that were previously released in hard copy and contain operating instructions, policies and procedures based on statutes, and guidelines and directives from CMS. Available publications include outpatient physical therapy, home-health agencies, skilled nursing facilities, etc.

After you've selected your manual, click "view and print." This will allow you to select a chapter to view. Chapter 2 of each manual is titled "Coverage of service" and will outline reimbursement under both Part A and Part B. Remember that the sections in red are those that CMS has recently updated.

Keep in mind, however, that CMS is gradually transitioning from paper-based manuals to Internet-only manuals (IOMs). Visit www.cms.hhs.gov/manuals/cmsindex.asp to read the manuals of interest to outpatient facilities, including Publication 100-2, Chapter 15, regarding basic coverage rules, and Publication 100-4, which covers billing for both Medicare Part A and Part B. Chapter 29 in this publication also walks therapists through the claims appeal process.

Visit www.cms.hhs.gov/manuals/IOMCrosswalk.asp to view available crosswalks. Publication 9 covers outpatient physical therapy and comprehensive outpatient rehabilitation facilities.

You can link to another useful site by clicking on "Program Transmittals" before selecting a chapter to view. Alternatively, by typing www.cms.hhs.gov/manuals/transmittals you can also view CMS' transmittal site. CMS usually posts transmittals to communicate new or changed policies. This primarily happens on Fridays so be sure to check for additions weekly.

The Office of Inspector General (OIG) maintains a list of all providers that have been excluded from participating in the Medicare program. Bases for exclusion include convictions for program-related fraud and patient abuse, licensing board actions, and defaults on Health Education Assistance Loans.

Got to http://oig.hhs.gov/fraud/exclusions.html to find research on potential new hires as well as any outside vendors with whom you are considering working. Not only will this help you avoid working with unscrupulous individuals and companies, it will also help you dodge any reimbursement difficulties that could result from billing Medicare for a service rendered by an excluded provider.

"Credentialing is not only important for payers and large employers, but for any size provider," says Mailly. Always verify licensure and the presence of any pending or prior disciplinary actions. This information is often available via online license directories from state boards and regulatory agencies. "We need to be aware of who practices in our facilities, and there is an expectation that we will do so," says Mailly.

Make yourself familiar with your local policies and regulations first, as they can often be more restrictive than national policies, says Mailly. "Start locally and then expand," he recommends.

For example, under Medicare, a therapist who is board-certified in clinical-electrical physiology can perform and interpret an electromyogram (EMG) and Medicare will reimburse for these services. If the therapist is not board-certified, Medicare will reimburse for performing the EMG, but not for the interpretation, according to Medicare. However, if this therapist practices in New Jersey, both services are prohibited by state regulations.

"If you knew your local standards, you would know that [it is prohibited]," says Mailly. "If you bill [Medicare] for the services anyway, you could find yourself being accused of fraud."

Visit your fiscal intermediary's (FI's) or carrier's Web site regularly, as well as the sites of any other carriers that work with your facility. Visit CMS' Medicare Coverage Database at www.cms.hhs.gov/mcd/search.asp to find yours, suggests Gawenda. Or, try www.cms.hhs.gov/contacts/incardir.asp#1 to search the CMS Intermediary-Carrier Directory.

By visiting your FI's Web site frequently, you will also become aware of any opportunities to comment on draft policies that could affect you and your facility in the future. "If your FI starts drafting a local policy, you want to know about it," says Gawenda. "It could affect your business and so you want to be able to comment on it."

Additionally, if you are a physical therapist and have questions regarding state licensure or professional standards where you practice, visit the Federation of State Boards of Physical Therapy Web site at www.fsbpt.org for additional information.

Most therapists, whatever their discipline, are interested in working hands-on with their patients. The thought of searching the Web for resources may mean time away from clients, but it will be time well spent. "PTs are people-people," says Mailly. "We prefer personal interaction, and the Internet can be very cold. But tip number one is [therapists] better get online."

Therefore, listservs can be a great way for you to interact with your peers across the country and trade ideas and solutions. Remember that the information shared in this format is an interpretation that you shouldn't necessarily take as absolute truth.

"Using listservs can be good for networking," says Gawenda. "But you need to distinguish between what is fact and what is someone's opinion."

And finally, the term, "if within the scope of practice" in any Medicare regulations is a code phrase that should prompt you to check your local policies. Here, CMS is telling therapists that a service is reimbursable if the individual state you practice in allows it, says Mailly.

"This is further evidence of the need to start locally, with your state laws and regulations, then expand your search from there."

Clip this list and keep these web addresses near your computer:

To join BRRR's Rehab Talk listserv, send an e-mail to owwer-rehab_talk@hcpro.com.

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