Upcoming Seminars: Documentation and Payment Issues in Outpatient Physical Therapy: Assuring Compliance & Avoiding Fraud and Abuse October 16-17, 2008 — Great Wolf Lodge, Mason, Ohio Payment & Policy Challenges in Outpatient Physical Therapy: Tools for Success in 2008 & Beyond! October 24-25, 2008 — Raleigh-Durham, North Carolina Audio Conference: The Advanced Beneficiary Notice: How to Legally Collect Cash from a Medicare Patient September 9, 2008 — Partnership with APTA Chapters Audio Conference: The OIG Self Disclosure Protocol: Should You Notify the Government if you suspect a Problem, and How to Minimize Your Risk of an Audit October 7, 2008 — Partnership with APTA Chapters Audio Conference (2 Part): Part 1: Establishing a Fee Schedule for your Facility: Using the Medicare Resource Based Relative Value Scale (RBRVS) as a Guide November 11, 2008 — Partnership with APTA Chapters Audio Conference (2 Part): Part 2: Determining Your Cost per Visit: Understanding Basic Financial Statements and Answering the Question: Should I Sign This Payer Contract? November 18, 2008 — Partnership with APTA Chapters Read more	Expertise & Consulting Services — Medicare Compliance Medicare is the largest healthcare payer in the country, and the number of rules and regulations that govern the program is overwhelming. As a physical therapist or provider of physical therapy services, the amount of time and effort required to keep current with the ever-changing environment is equally daunting. Physical therapy services represent one of the fastest growing categories of costs under the Medicare program, and as a result, the federal government has been increasing its efforts to eliminate over utilization and potential fraud and abuse among providers who bill for physical therapy services. Although the Medicare Therapy Cap Exceptions Process has allowed beneficiaries who need these services to receive them when medically necessary, this process can be very confusing. What is more alarming is that accessing the Exceptions Process in the absence of documentation that justifies medical necessity will place the physical therapist and/or facility at risk for potentially committing fraud and abuse. However, Medicare compliance is not limited to the Therapy Cap and Exceptions Process. It is critical to ensure you are compliant with Medicare’s definition of skilled care, as well as the coverage limitations and “reasonable and necessary” requirements identified in the multiple Medicare regulations and manuals. Specifically, Medicare compliance issues that put physical therapy providers at risk include the requirement of qualified professionals to provide therapy services, appropriate use of waivers and modifiers, supervision of assistive personnel, the Correct Coding Initiative (CCI) program, certification requirements, adherence to minimal documentation requirements, and adherence to Local Carrier Determinations (LCDs). RCRI can assist in assessing your risk associated with Medicare compliance issues through: Assessment of compliance with Medicare rules and regulations relating to outpatient physical therapy and other rehabilitation services Assessment of compliance with Medicare’s “skilled care” requirements Assessment of compliance with the Medicare Benefit Policy Manual Assessment of appropriate applications of waivers (i.e. Advanced Beneficiary Notification (ABN), Notice of Exclusion from Medicare Benefits (NEMB)) Assessment of appropriate use of modifiers and review of documentation to support their use Assessment of risk related to Correct Coding Initiative (CCI) and other edit initiatives that effect payment Assistance with Therapy Cap issues and compliance Assistance with understanding and compliance of Therapy Cap Exceptions Process Assessment of compliance with new Medicare minimal documentation requirements Assessment of supervision compliance regarding assistive personnel Assessment of compliance with certification requirements and other components of technical compliance under the Medicare program Development of documentation templates that incorporate minimal documentation requirements under the Medicare program Provide recommendations regarding the use of attorney/client privilege during audit or investigation that may provide greater protection of the provider in these circumstances Identification of areas of risk related to potential Stark ramifications in the areas of ownership, joint ventures, fee splitting, kickbacks, or inducements. Education and training in criteria for documenting medical necessity and skilled care Assistance in understanding specific local Carrier and Intermediary coverage determinations Staff education and training in the area of Medicare compliance Provide non-punitive audits to assess statutory compliance with Medicare regulations and other third-party payer requirements Provide resources to facilitate legal consultation with expert Medicare attorneys in any of the following areas: reimbursement issues, compliance, contacts, joint ventures, other federal law issues (including fraud and abuse concerns), Stark issues, and the new privacy laws Provide resources to facilitate legal representation in matters pertaining to Medicare/third party reimbursement