RAC Audit Plan of Care and 8 Minute Rule

RAC Audit Plan of Care and 8 Minute Rule
The Plan of care (POC) is what will make or break you in an audit. Physical Therapists often get hurt during the RAC audit when their POC is not well documented and/or in some cases even adhered to. It really comes down to how you document a medical necessity. When CMS first starts the audit, they will take a few charts. When they see problems with the POC on a reoccurring basis, that will instantly set off a series of demands for more charts.
The 8 Minute Rule tells us that you can only bill a maximum of 4 units per hour. Be we need to admit that not all sets of 8 minutes were created equally.
Are you seeing multiple patients at the same? Medicare clearly states that total billable time is decreased when you are going back and forth between patients.
Are you seeing medicare and private patients at the same time? Again, Medicare does not allow Physical Therapists to go back and forth between Medicare and private payees.
Do you provide skilled intervention or a maintenance program? The key here is that the patient needs to keep making progress. If they are not making progress, make sure you’re easing the PO every 3-4 weeks. Then, tell them to see their doctor to get a new prescription.
Red Flat: Watching your patients exercise is not billable.
Red Flag: Application of heat is not a billable service in and of itself. What if you ask the Patient to clench a ball while you apply heat? That is a therapeutic service, but I call this a major gray area. Remember, you cannot bill Medicare for maintenance, but only skilled intervention.
RAC Audit Plan of Care and 8 Minute Rule