T-Minus 3 Months and 16 Days Until the Implementation of the CMS Claims-Based Data Collection Requirement for Outpatient Therapy Services

As BESLER has previously alerted you, new CMS requirements regarding Outpatient Therapy reporting will impact your payments in less than 4 months. You should be using the “Grace Period” being provided by CMS wisely to avoid going over the Therapy “Fiscal Cliff” come July 1, 2013.

Are you prepared and aware of the financial consequences if you are not ready for the July 1^st implementation date?

As of July 1, 2013, CMS will begin return to provider (RTP) of all Therapy claims without the required G-codes and modifiers. This has the potential for a dramatic impact on your organization’s cash flow if you have not ensured that the Functional Reporting G-codes/modifiers have been reported appropriately on your uniform bills (UBs). If the documentation of the G-codes does not appear in the Therapist treatment notes, you will not be able to retroactively add the codes to the documentation; resulting in not just delayed but permanent loss of reimbursement. Additionally, any other ancillary charges appearing on the returned claims will result in delayed reimbursement.

Have your Clinical and Financial Information Systems been updated to accept the new documentation and billing requirements?

All clinical and financial systems will need to be updated in order to ensure that the new documentation and billing requirements can be reported appropriately. Has your charge description master (CDM) been updated? Have the charging and ordering screens been updated? Have you added edits to your claim scrubber to ensure that clean claims are going out to CMS?

Have you audited your Q1, 2013 Therapy Claims?

Pre-implementation audits should be performed on a monthly basis from now until July 1, 2013 to ensure that clean claims are being submitted to CMS. A multidisciplinary team should be identifying opportunities for improvement in documentation or claims reporting as well as remedial education for the staff.

BESLER is prepared to assist your organization with the implementation of Claims-Based reporting for your Therapy Department with the following services:

• Up front training of PFS, Therapy and Health Information Management (HIM) staff to include coding, reporting milestones and documentation education.
• Assistance with setting up the codes in your clinical system and developing an operational implementation plan.
• Sample audit of claims to ensure that your facility is using the code sets properly, minimizing the potential for claim delays.

If You Want More Information

For further information on support services for the implementation of Claims-Based Therapy Reporting; please contact Jeff Lampman, Vice President of Client Development at 732-392-8223 or jlampman@besler.com.

Who Is Affected

The following providers: Acute Care Hospitals, Critical Access Hospitals (CAHs), Skilled Nursing Facilities (SNFs), Comprehensive Outpatient Rehabilitation Facilities (CORFs), Rehabilitation Agencies, and Home Health Agencies (HHAs) (when the beneficiary is not under a home health plan of care). The following practitioners are also affected: Therapists in Private Practice (TPPs), Physicians and Non-Physician Practitioners (NNPs) such as Nurse Practitioners (NPs), Certified Nurse Practitioners (CNPs) and Physician Assistants (PAs)².

 

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