Burdensome 2020 Medicare Requirements.
Can’t This Just be Automated?
New Modifiers for 2020
At first blush, the new Assistant Modifier Designation is little more than a CQ modifier for PTAs and a CO modifier for COTAs. However, a deeper analysis of the CMS’ final rule clarifies that the new assistant modifiers are yet another time-consuming audit trap.
Documenting minutes separately for therapists vs. assistants is one thing. But allocating therapist/assistant treatment content with the typical counterintuitive Medicare rules gets confusing in a hurry. For example, when 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 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.
After the therapist and assistant have huddled to sort out who delivered what and how to charge for it (which they don’t have time to do), the 2020 final rule requires, “… 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.”
The practice owner is once again left with two unacceptable options:
- Document with less-than-stellar compliance. Just as they did with defending the severity of eval codes, your EMR leaves compliance up to you as it relates to the new assistant modifiers and defensive documentation
- Explain to your therapists (who already spend their nights and weekends catching up on documentation) that documentation time has just increased for every Medicare date of service
As your EMR tells you, “We’re ready for 2020,” we encourage you to step back and look and ask the question:
Is your EMR the solution to subpar compliance and therapist burnout,
or it your EMR part of the problem?
Proceeding by manually parsing out therapist vs. assistant treatment content, then manually documenting the same detail for each CPT code, is wrong-headed. It’s not your job.
Your job is to restore the patient’s functional deficits.
Systems 4PT Automates Unit Charges and Assistant Modifiers
New for 2020, Systems 4PT’s technology intuitively segregates therapist treatment content from assistant provided services. Automation instantly recommends the defendable unit charges and applies them to the appropriate provider with the compliant modifier, cognizant of the CMS vs. AMA coding requirements, and complete with specificity detailing “who provided what services,” all in the blink of an eye.
When documenting a Medicare evaluation with Systems 4PT, patient-specific documentation appears “touch-free”
When documenting a Medicare evaluation with Systems 4PT, patient-specific documentation appears “touch-free” for the 12 evaluation topics listed below:
- Patient’s Greatest Concern
- Prior Level of Function
- Pain Scale
- Outcome Test Name, Date, and Score
- Medical History
- Current Medications, Dosage, Frequency, and Route of Intake
- Your Unique 20 to 50 Row Treatment Plan, Archived from Your Diagnosis and Risk Factor Specific Library
- Primary Functional Deficit With Forecasted Ending Severity
- Functional Goals That Relate to the Primary Deficit
- Defense of the Severity of the Eval Code
- Clinical Rationale Defending Every CPT Code in the Treatment Plan, Relative to the Primary Functional Deficit
- And For 2020: Defensive Documentation That Details Which Provider Delivered How Much of Each Exercise, Treatment, and Modality, Complete With Appropriate Assistant Modifiers