Cotreating can lead to double billing trouble

Rehab Regs, June 29, 2005

If you provide cotreatment with another therapist, be careful how you bill. If you don't master the correct way to document your time with this patient and bill accordingly, you could get nabbed for double billing. Read on to find out how to avoid an audit.

Consider this example: You work with a patient on gait training and need an extra pair of arms to assist you. You enlist the help of another therapist, and by the end of the treatment, both of you have spent a full hour with this patient. When it comes time to submit a claim, for how much time should you bill?

An easy way to remember the correct way to bill is to think of the patient's time in therapy rather than the therapists', says Ann Lambert Kremer, OTR/L, MHSA, CPC, a consultant with Beacon Rehab Solutions in Portland, ME.

"Therapists should document separately, but when they bill, they should be billing for the time the patient spent in therapy," says Kremer. "This is all Medicare will allow."

Here's another example: A PT works on trunk control while an OT works with the same patient, at the same time, on an activity of daily living. The patient benefits because the session helps him or her build strength while performing a task that he or she will likely have to do at home.

"The patient can be working on trunk control in a functional exercise rather than just spending time in therapy," says Terry Cichon, CPA, director of healthcare operations for FR&R Consulting in Deerfield, IL.

That is, one therapist can bill for the 60 minutes of treatment, or each therapist can bill for 30 minutes of treatment time, as long as both therapists provided skilled treatments that were medically necessary.

In some cases, if the patient's needs allow one therapist to be substituted for an aide or an assistant, this may be a more cost-effective route. When two therapists treat together, one forgoes another patient whose treatment he or she could bill for.

"Two minds are better than one, and [cotreating] should be done with complex patients," Kremer says. "But in other cases, it's more efficient to use an aide or an assistant."

However, if you feel that a patient can benefit more from two therapists, you may want to forgo the additional reimbursement and productivity to ensure that you provide the patient with the treatment he or she needs.

"If I'm cotreating for a full hour and can only bill for 30 minutes, I was technically 'nonproductive' for the other 30 minutes," says Cichon. "But it's more important that the patient receives proper treatment."

But just because Medicare doesn't allow double billing for cotreatment doesn't mean all other payers do. "Some of your patients might have private insurance or workers' comp, and those payers could view it differently," says Kremer. "If you felt cotreating was truly in the patient's best interest, you could call and ask the payer for permission to do so."

Your carrier or fiscal intermediary (FI) might not know whether you double bill unless it looks at the documentation in your charts. But this isn't a chance you want to take, says Lee Heinbaugh, controller for PMGO, Inc., long-term care consultants in Cleveland. You could fall under audit scrutiny and have to pay the money back if you're caught.

"The first time, [your carrier or FI] will usually dis-allow it and put you under review so it doesn't become a habit," says Heinbaugh. "If you've been told it's wrong and you continue to do it, now you're billing inappropriately to a federal program."

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