CMS Announces Additional Outpatient Occupational Therapy Billing Changes
In August 2006, the Centers for Medicare and Medicaid Services (CMS) issued guidance to Medicare contractors instructing them to initiate additional code edits for certain outpatient therapy services. Under the Deficit Reduction Act of 2005, CMS is required to implement clinically appropriate edits to eliminate improper payments for outpatient therapy services.
Accordingly, CMS requires that the codes represented on the chart (see Related Content at right) may only be billed at or below the number of units indicated on the chart per treatment day. When higher amounts of units are billed, the units that exceed the limit shall be denied as medically unnecessary, however, denied claims may be appealed. An Advance Beneficiary Notice (ABN) is appropriate to notify a Medicare beneficiary of his or her liability.
CMS' occupational therapy service edits are appropriate and do not harm occupational therapists. All of the codes chosen for service edits that affect occupational therapists are "untimed" codes, and under Medicare rules should not have been billed for more than one unit per treatment day even before the issuance of the CMS guidance. In this transmittal governing additional Deficit Reduction Act mandated service edits, CMS is emphasizing a rule for untimed codes that already existed and was being followed by occupational therapists to avoid improperly billing the Medicare program.
To read the full text of the CMS guidance, see http://www.cms.hhs.gov/transmittals/downloads/R1016CP.pdf