Chuck,

I have not encountered any physicians billing for OT up here in the UP - 
they're working for either Marquette General or one of the local hospital 
affiliates of same or one of the other two "independent" hospitals in the UP 
who have out patient, in patient and home care A and B services.  We do have 
two physicians here in town who left OSF St. Francis based in Peoria, IL to 
strike out on their own.  Unfortunately they're not in the phone book yet so 
who knows how they're doing.

My gut tells me though that if Medicare is worried about OT and PT in 
private practice flooding Medicare with billing what do they think 
physicians would/are doing?  It's a whole lot easier to work for an MD than 
set up your own practice.

Just as a question - what about all the therapy agencies that are billing 
for hours of therapy when their therapists are seeing multiple patients at a 
time - billing for many hours of therapy while only in the building 
delivering services for 50-80% of the billable hours?   There is no way for 
Medicare to be aware of this or to track this - the SNF is billing for the 
therapy, not the therapy agency or therapist.  Only if Medicare asked for 
the therapists' billable hours would the potentially questionable delivery 
of services be found.

Take care - enjoying being a Dad - Little ones are spectacular as they learn 
and "get wheels", walk when you're really too tall to give them a finger for 
support (or you'll have a really bad back before they're 2!), learn to talk 
and ask so many questions, then grow and decide you're a "fuddy duddy", and 
again grow and decide that what you thought was a good idea (like keeping a 
fire pathway to the door from the bed in their bedroom) is, in fact a great 
idea, and their organizational skills are stupendous.  Don't ever wait for 
them to learn how to iron their military uniform when they're home for a 
visit though - that will fall to you or your wife - which ever has that 
unique skill. (Yes, I just completed ironing the NOAA Corps's 26 year old's 
uniform - teaching again how to do this - while on shipboard she has 
succeeded in conning the others on shipboard to do this for her - my hubby 
says a women has to be beautiful, smart or rich to succeed, the 26 y/o is 
beautiful - well, admittedly not an unbiased opinion, - and smart so 2 out 
of 3 is pretty good.)     :)    Laura W.




----- Original Message ----- 
From: "Chuck Willmarth" <[EMAIL PROTECTED]>
To: <[email protected]>
Sent: Friday, August 03, 2007 3:02 PM
Subject: [OTlist] Referral Relationships Between Therapists and Physicians


>
> AOTA Seeks Feedback on the Referral Relationships Between Therapists and
> Physicians
>
> Should therapists be able to work directly for physicians?  As part of
> the proposed rule on the Medicare Physician Fee Schedule for 2008, CMS
> is considering changing the Stark anti-kickback rules about in-office
> ancillary services. Current policies permit physician ownership of
> occupational therapy practices, permit physicians to bill for
> occupational therapy services other than through incident-to billing,
> and allow situations where occupational therapists reassign Medicare
> reimbursement to a physician practice.   Would a change forbidding
> physicians to "own" therapy practices or use therapists as part of
> practices they own other than when providing services "incident to."
> AOTA will be commenting on this issue, as well as other aspects of the
> proposed fee schedule rule, and seeks feedback on how these issues have
> impacted you.
>
>
> Read more about the issue at
> http://www.aota.org/News/AdvocacyNews/40312.aspx and provide feedback to
> AOTA at [EMAIL PROTECTED] by August 15th for inclusion in our official
> comments.
>
>
>
> Chuck Willmarth
> Director, State Affairs
>
> -- 
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