This is from the PPS Final Rule, page 41661, July 30, 1999
<<QUOTE
The rehabilitation therapy service must be
ordered by a physician. The Medicare
policy regarding the requirement for the
physician signature on the therapy plan
of treatment has not changed. As is
stated in the SNF Manual, rehabilitation
therapy services provided to a
beneficiary in a SNF must be directly
and specifically related to an active
written treatment plan established by
the physician after any needed
consultation with a qualified therapist.
Implementation of the PPS did nothing
to alter this guideline. We will,
however, take this opportunity to clarify
what is required for coverage of
rehabilitation therapy.
As stated in the language in the SNF
Manual cited in the preceding
paragraph, Medicare requires the
physician to make decisions regarding
the amount and intensity of
rehabilitation therapy services provided
to Medicare beneficiaries in SNFs
after consulting with the professional
therapist. This requirement is based on
our commitment to ensuring quality
care for Medicare beneficiaries, and also
reflects the requirements for
participation (at section 1819(b)(6)(A) of
the Act), which specify that the medical
care of every SNF resident must be
provided under the supervision of a
physician. Our policy has not changed,
and we are taking this opportunity to
clarify that policy. The physician's
responsibility in the development of a
rehabilitation therapy plan of treatment
ensures that the services to be provided
will not exceed the beneficiary's
abilities as constrained by his clinical
status. In addition, we believe that the
physician's clinical judgement is an
important aspect in preventing injuries
that can result from the provision of
inappropriate rehabilitation therapy. For
example, the rehabilitation plan of
treatment for a beneficiary with a hip
fracture should be developed with an
awareness of his or her limitations due
to severe osteoporosis and emphysema.
Unless the beneficiary's entire clinical
condition is taken into account, there is
a significant risk of injury and of a
compromised medical status.
We expect that the same care will be
taken by the physician and SNF staff to
document physician responsibility for
developing the therapy plan of
treatment, including precautions, that is
reasonably expected to be taken for any
other element of the medical record. We
realize, however, that in the SNF setting
there may not be a physician on the
premises every day. Therefore, Medicare
allows the professional therapist to
develop a suggested plan of treatment
and to begin providing services based
on that plan prior to obtaining the
physician's signature on the plan. We
continue to require that the plan of
treatment must be a physician's
responsibility after any needed
consultation with a qualified therapist,
and that the requirement for physician
verification of the suggested plan of
treatment will be obtained within a
reasonable amount of time. However, a
physician signature must be obtained
before the facility bills Medicare for
payment for the rehabilitation therapy
services provided to the beneficiary
based on the plan of treatment he or she
has approved. In this way, the facility
can be sure that the level of therapy for
which it bills Medicare is the level the
physician deems to be medically
necessary. We expect that the type and
intensity of therapy billed will always
match the type and intensity of therapy
on the signed therapy plan of treatment.
We understand that many physicians
use the fax to participate actively in the
review of written plans of care and so
believe that it is appropriate to accept
physicians' faxed signatures for the plan
of treatment. As always, whenever the
plan of treatment is altered in any way,
the modification must be made in
writing. If the physician is not the
person making the modification, the
therapist who is making the change
must notify the physician timely, and
the physician must sign the change
within a reasonable amount of time.
visual contact with the aide at all times.
>>END QUOTE
Rena
Rena R. Shephard, MHA, RN, FACDONA, RAC-C
Chair, American Association of Nurse Assessment Coordinators
[EMAIL PROTECTED]
Subj: RE: Therapy orders
Date: 1/14/04 10:09:06 AM Pacific Standard Time
From: [EMAIL PROTECTED]
Reply-to: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Sent from the Internet
This is what our orders say also. I would think if you included exact
minutes you could get into trouble. If a resident was not able to
tolerate that minutes for that day, you would have to call physician,
etc. I think what Rena is referring to is that the order must include
modalities, number of times per week, and how many weeks to be treated.
Is that right, Rena?
Brenda W. Chance, RN, RAC-C
MDS Coordinator
