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Satisfying the Active Participation Rule When Working with PTAs

Mary R. Daulong, PT, CHC, CHP

August 27, 2012

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Question

If a patient sees a Physical Therapy Assistant for four weeks in an aquatic setting, does the PT have to see the patient in the aquatic setting at least once in that timeframe to satisfy the active participation rule that you mentioned?  And does the regular reassessment count for a visit for the PT under the active participation rule?

Answer

The PT has to deliver one billable service.  If the only thing that has been done for four weeks is aquatics, then yes. However, I will tell you that when you are not simultaneously doing land based services, you will have a problem with having a red flag from Medicare.  Unless your patient is a mermaid, they have got to move to land to be functional.  There may be an exception if they are in a pain management program.  But patients should move forward.  So, if you are billing only for aquatic therapy for four weeks in a row, you are not showing progress.  Maybe you are showing progression with the things they are doing in the pool, but you are not moving to functional progress.  

Does the reassessment count as the treatment?  If the PT saw them before the 30th day or the 10th visit, and if they treated the patient on the day that they completed the progress report, yes. Is it dangerous to wait to the last day?  Most assuredly!

 

 


mary r daulong

Mary R. Daulong, PT, CHC, CHP

Mary Daulong, PT, CHC, CHP has a very diverse practice background which includes private practice ownership, corporate managed services and hospital based practice exceeding four decades. Her consulting company was established in 1985 and has been, for the past ten years, 100% dedicated to working with healthcare professionals in the areas of federal and state compliance, practice and business office operations, payment and coverage policy including billing, coding and documentation. Her company also provides rehabilitation specific compliance policy and procedure manual production and provider enrollment services.

Mary has been certified in Health Care Compliance since 2002 and is a member of the Healthcare Compliance Association she is also certified as a HIPAA Professional by the HIPAA Academy. Mary has been an active member of the APTA and just recently served as its Risk Management Committee chair. She is a member of the APTA’s State Reimbursement Chair Forum and has held the position of Chair of the Texas Physical Therapy Association’s Payer Relations and Payment Policy Committee for nearly six years.  She served for five years on the Texas Board of Physical Therapy Examiners as well as was a member of its Executive Council for PT and OT and Investigations.

 Mary has presented well over one hundred (100) courses related to compliance both on a federal and state level often being the featured speaker at National, Chapter and Section Annual Conferences.


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