Re: [OTlist] COTA documentation regulations

[Joe Wells]

Pat:   I reviewed the Medicare Carrier's manual (for outpatient under Part B) and, the medicare regs for therapies as on your intermediary's (United's) website. I am assuming that your company is not starting an outpatient clinic as a private practice or group practice, it seems that they wish to provide outpatient as a rehab agency and thus, are governed under the intermediary. Only CORFs/ rehab agencies have survey requirements. However, I am still a little confused as why did they go to the SNF to do the initiation survey? And, is your company trying to start outpatient services at the SNF. Well, you should be able to do that with the SNF's current enrollment status. Or, is your SNF starting a free standing clinic as well, with a different medicare # for seperate liabilities? Eitherway, found nothing that stated COTAs cannot document on progress notes,. However, note that the other criteria that clearly shows the OTR is supervising the program adequately and performing ongoing assesment/ adjustments to the plan as needed must be met.   I found the following on CMS site pertaining to PTAs (go to page 32 of the document). From my experience, and going over the carrier's manual, SNF manual and your intermediary's LMRPs, I am unsure of what your surveyor is talking about. I am thinking she confused OTA for OT aide. http://www.cms.hhs.gov/medlearn/therapy/finalpta802.pdf (an interesting read- also shows you what the PT profession is seeking in future as well) http://cms.hhs.gov/medlearn/therapy/faqinfo.asp (READ THE ASSUMPTION SECTION) ----- Original Message ----- From: Jimmie Arcenaux To: '[EMAIL PROTECTED]' Sent: Monday, July 14, 2003 9:57 AM Subject: RE: [OTlist] COTA documentation regulations I reviewed the California practice act and there is nothing in that preventing an OT Assistant from documenting.  I know for a fact that there is nothing in the Medicare conditions of participation which would limit this.  You may try your fiscal intermediary.  There may be some ruling based solely in California.  You may view the SNF regs at http://ptmanager.com/snf.htm and general outpatient regs at http://ptmanager.com/outpatient.htm.   Jimmie     -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Sunday, July 13, 2003 1:45 PM To: [EMAIL PROTECTED] Subject: [OTlist] COTA documentation regulations   I reside in California and recently had a state surveyor review our SNF facility.  The company I work for is looking to expand into outpatient services at this facility.  When the surveyor reviewed O.T. documentation and found that a COTA had documented a weekly progress note, I was told that COTAs are not allowed to write weekly progress notes.  My understanding was that they were allowed to do so, but of course OTRs are to complete all other documentation.  I work closely with the COTAs on a daily basis and I review weekly the patient's progress with them.  The COTAs I work with have 20 years experience and I feel are very capable of performing this documentation.  The surveyor stated Title 22 Section 72413 and section 72401 of the Medicare codes, but I am unable to locate this.  Can anyone help me out as now our facility is looking at a deficiency and I am told that COTAs are no longer able to perform any documentation.  Thank you