Quick Check: Are You Compliant With Medicare’s New 2020 Compliance Requirements?

Outpatient rehab is dangerously vulnerable to Medicare’s new 2020 compliance requirements.

Is this true with your practice?

Most therapists are unaware of Medicare’s new 10% de minimis rule.

A common misperception is that “PTA modifiers are not required until 2022.”

This mindset will prove to be expensive when audited.

Why PTA Modifiers Are Required NOW

Although it’s true that the 15% assistant fee reduction doesn’t begin until 2022, pages 447-471 of the 2020 CMS final rule clarify and specify that all the following topics are requirements, beginning January 1, 2020:

Assistant modifiers
Application of the 10% de mimimis rule
Specified defensive documentation

The Audit Implications for Your Practice

Audit implications have nothing to do with a 15% takeback. Those reductions don’t arrive until 2022. However, if Medicare documentation does not comply with the three points listed above, the auditor has a green light to demand a total takeback. And remember, Medicare’s new 2020 rule is required on every date of service, not just the evaluation.

These compliance changes are required right now, today.

Most EMRs have failed to respond, putting it all on your practice.

Is your practice being left vulnerable to takebacks?

How To Comply with Your Current EMR

All treatments and exercises provided independently by an assistant must be billed with the appropriate CQ or CO assistant modifier.
Medicare’s 10% deminimis rule determines whether CPT units are charged to the therapist or the assistant. You must apply this rule to every code and calculate therapist time versus assistant time.

For example, if the therapist delivers 10 minutes of therex (even though this exceeds the 8-minute threshold) the therapist cannot charge 1 unit of therex if the assistant independently delivered any therex to the same patient. That unit must be charged with the assistant modifier. This is just one example and it’s by far not the most complex.

Finally, Medicare requires that your documentation defends the therapist/assistant content of every CPT is documented on every date of service. Quoting the final rule:

“…. the documentation in the medical record [must] be sufficient to know whether a specific service was furnished independently by a therapist or a therapist assistant, or furnished ‘in part’ by a therapist assistant in sufficient detail to permit the determination of whether the 10 percent standard was exceeded.”

If your practice includes PTAs or COTAs,

Medicare documentation must comply with these points for every date of service.

How to Comply in Under 10 Seconds

Systems 4PT provides a 10-second workflow that enables your practice to comply with each of these requirements. Our practices have been compliant since January 2, 2020.

Your EMR has let you down, leaving you completely vulnerable.

Take a look at Systems 4PT over lunch one day next week. You’ll see up-to-date compliance, faster notes, and collections that have been stable since 2012, all for less than you pay today for EMR and billing.