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Preparing for New Medicare Reviews in 2020

By RehabCare

Are you prepared for audits as announced by CMS and their Medicare Administrative Contractors (MACs)? CMS has shifted the audit focus to Part B reviews for specific billed CPT codes. Through the Targeted Probe and Educate (TPE) Program, MACs are currently identifying providers with higher-than-average utilization for CPTs 97110, 97530, 97112, and 97140 and conducting pre-payment reviews of the medical record to support the billing of these services and to ensure that all Medicare requirements are being met.

Preparing for New Medicare Reviews in 2020

Unlike previous audits, these reviews will focus solely on therapy documentation. In order to meet requirements, the record must support the medical necessity for all billed services and demonstrate that the treatment is approved in a timely manner by the physician.

To prepare, certain technical and qualitative document requirements must be met:

  • Confirming that therapy orders are present in the chart before evaluation
  • Monitoring for timely MD signature of all POCs/UPOCs and secure delayed certification if needed
  • Ensuring progress notes highlight a summary of specific skilled interventions delivered to the patient (including patient/caregiver training with outcomes/carryover noted) and document changes implemented during that progress period (plan modification, upgrades, adjustments in challenge level, etc.)
  • Supporting therapist involvement in the daily notes with reference to specific skilled teaching and facilitation techniques (avoid generic statements that may be interpreted as representing repetitive and routine services)

In addition to these additional requirements, planned speech therapy audits were recently announced by the Office of Inspector General (OIG) for 2020. These reviews will have a focus on ST Part B claims that have exceeded the therapy threshold ($2,080 when combined with PT) and billed with a KX modifier. It is predicted that these reviews will mainly focus on the services billed over the threshold and place increased scrutiny on the justification for ongoing services that require the clinical expertise of a qualified speech-language pathologist.

Don’t delay on preparing for possible TPE reviews and audits -- now is the time to improve documentation practices and internal audit activity. RehabCare has a team of specialists in the areas of quality, auditing and appeals who are ready to partner with your facility in ensuring that you are up to date with Medicare regulations and can assist you throughout the entire audit process. To learn more about partnership options that will enhance your organization’s existing operations, contact RehabCare today at 1.800.545.0749 extension 67640. 

By RehabCare