Question: Can rehab aides do gait training and balance training? I just want a specific answer to my question. And if it's ok, can bill it? How will you bill this to Medicare A and Medicare B? How about the documentation?

Answer: Absolutely not. There is not a practice act in the country that would state that an aide is qualified to provide this level of expert care. Under Part A, a rehab aide is allowed to provide "support services" under the direct line of sight of a therapist or therapist assistant, but they cannot provide skilled therapy services. With regard to gait training and balance training, the aide does not have the expertise to provide that level of care. Under Part B, rehab aides cannot provide any care that is billable.

Question for thought: If the patient was your loved one, would feel like you got your money's worth if their care was provided by a rehab aide rather than a therapist or therapist assistant?

 
Question: When we reviewed some of our outpatient charts we discovered that we were missing some certifications, mostly because the physicians didn't return them to us. What should we do?

 Answer: You should obtain a delayed certification. CMS Pub. 100-02, the Medicare Benefit Policy Manual, Chapter 15, Section 220.1.3 D Delayed Certification states, "Certifications are required for each interval of treatment based on the patient's needs, not to exceed 90 calendar days from the initial therapy treatment. Certifications are timely when the initial certification (or certification of a significantly modified plan of care) is dated within 30 calendar days of the initial treatment under that plan. Recertification is timely when dated during the duration of the initial plan of care or within 90 calendar days of the initial treatment under that plan, whichever is less. Delayed certification and recertification requirements shall be deemed satisfied where, at any later date, a physician/NPP makes a certification accompanied by a reason for the delay. Certifications are acceptable without justification for 30 days after they are due. Delayed certification should include one or more certifications or recertifications on a single signed and dated document.

Delayed certifications should include any evidence the provider or supplier considers necessary to justify the delay. For example, a certification may be delayed because the physician did not sign it, or the original was lost. In the case of a long delayed certification (over 6 months), the provider or supplier may choose to submit with the delayed certification some other documentation (e.g., an order, progress notes, telephone contact, requests for certification or signed statement of a physician/NPP) indicating need for care and that the patient was under the care of a physician at the time of the treatment. Such documentation may be requested by the contractor for delayed certifications if it is required for review.

It is not intended that needed therapy be stopped or denied when certification is delayed. The delayed certification of otherwise covered services should be accepted unless the contractor has reason to believe that there was no physician involved in the patient's care, or treatment did not meet the patient's need (and therefore, the certification was signed inappropriately)."

Disclaimer: The answer provided is based on Medicare guidelines. The provider should be aware of the other regulations that might supersede the Medicare payment guidelines. The information provided is current as of the time of publication.

If you have a question about Medicare reimbursement you would like the authors to address, send your question and contact information to Medicare Advisor, c/o Lisa Lombardo, ADVANCE for Physical Therapy and Rehab Medicine, 3100 Horizon Dr., King of Prussia, PA 19406; fax 610-275-8562; llombardo@advanceweb.com

You may contact the authors at Encompass Consulting and Education, LLC, a company specializing in Medicare compliance, consulting and education services at www.encompassmedicare.com.