If your practice is growing and you hire a new therapist, or plan to take a vacation and have a therapist cover for you, I congratulate you. You deserve it. But make sure you are aware of this important aspect of billing in order to avoid potentially serious problems later.
This article can save you from headache and scrutiny later.
Since this is an important topic that is riddled with confusion, I’ll cut straight to the chase.
Important Information: We, as physical/occupational therapists, do not have “incident to” allowances afforded to us like physicians. In layman terms, we cannot have another therapist substitute for us and bill under our provider number.
Hiring a New Therapist
Start the credentialing process right away and submit your application immediately. Hold all claims and don’t submit them until the new therapist receives their provider number. You have up to 1-year to submit claims. The process should take less than 90-days. If it lasts more than 90-days, file a complaint directly to CMS. Medicare will go back to the date the application was submitted as the start date so make sure all claims submitted fall within that time frame.
- Non-Medicare Insurances
If the new therapist is not credentialed with a particular insurance, and the new therapist is working alongside another therapist who is credentialed, make sure to have the credentialed therapist co-sign the new therapist’s notes. Some non-medicare insurances do NOT have any specific language on this matter in their contracts but even so I would play it safe and co-sign the notes.
Hiring a PRN/Registry/Contract Therapist (“Temp”)
Make sure the “Temp” therapist is credentialed with medicare and has a provider number. Most reputable registries vet their therapists well and require this but it doesn’t hurt you to make sure.
- Non-Medicare Insurances
This one is a slippery slope. If your Temp is not on all your other non-medicare insurances, check your particular contract(s) to see if there is any language on this topic. If no language exists, it’s up to you how you handle it. I would recommend having another therapist (who is credentialed) present during their service but if that’s not possible, at the very least, make sure to co-sign all the notes. If there is no language in your contract with the insurance on this matter, it’s hard-pressed to say that you have done anything wrong. I am in no way telling you what to do, just voicing an opinion.
If You Have Made a Mistake
“I have unknowingly billed Medicare for services rendered by a non-credentialed therapist in the past.”
- Contact me privately and I can help determine the severity of the situation.
- If your situation is severe, I can recommend how to find a knowledgeable attorney who can help fix the problem so you are not vulnerable for fraud charges. The government is very aggressive with their “fraud/abuse” campaign and can be overzealous. Read more here.
“I accidentally billed a non-Medicare insurance for the services rendered by a non-credentialed therapist in the past.”
- If there is no specific language on the matter in your contract, I wouldn’t worry about it. However, I would take heed to my recommendations given above from now on.
- If specific language exists in your contract stating you are not to utilize a therapist that is not credentialed, contact me privately immediately.
I have one last recommendation. Check your malpractice/liability insurance plan and see what the coverage limit is for legal representation in case of audit/scrutiny. Most policies only cover $10k to $25k. In this day of audit and scrutiny, I personally feel better having between $50k to $100k. It might cost you a little more now but could save you a lot later.
I hope this helps you have a little more peace-of-mind knowing how to go about new or temp therapists. I know it takes a little more work on your part but don’t worry too much. Get out there and grow your practices! Hire more new therapists and go on more vacations! Join us for more in Hawaii in November!
>>>For more information on billing, collections, coding, and audit-proofing your documentation, take the upcoming Advanced Billing Course by IndeFree