Therapists can co-treat? Why yes, they can!
Shelly Mesure, MS, OTR/L
Have you heard? Yes, it's true. We can now provide therapy co-treatment with another discipline WITHOUT splitting our treatment time. But, not so fast …
If we provide co-treatment in any shape or form, we must provide strong documentation on the co-treatment session and relate our role specifically to our discipline's scope of practice and patient goals. So, that doesn't seem so tough: Just document. Well, we have also seen claims denied because the documentation appeared as if services were being duplicated. So I recommend we use this new ruling sparingly.
I do recognize the full benefits this can produce, such as, no longer “fighting” over a resident if there are scheduling conflicts and two disciplines must treat the patient before the end of their shift. I also see this as an opportunity to enhance some levels of care when four hands are required to help the most dependent of patients. However, I feel we are potentially at risk with some companies attempting to abuse this option by requiring co-treatments when not clinically appropriate.
Therefore, I recommend you use this sparingly and make sure you have strong documentation to show how both disciplines' scopes of practice are indicated. I have several concerns with the documentation aspect. We are not required to indicate co-treatment procedures on billing logs; therefore, the responsibility primarily falls on the individual clinicians to document this service through a narrative note. If one discipline provides the proper documentation and the other discipline “forgets,” it could create a whole new set of headaches during an audit.
The other concern I have is regarding documenting medical necessity. As I have previously stated, we have been denied medical necessity and claims have been lost if the reviewer feels we have duplicated services. The reviewer/auditor may approve one discipline but deny the billable minutes from the other discipline that is accused of duplication of services. This results in a portion of the therapy minutes being denied, which could significantly lower the current RUG payment rates. There also may be “sloppy” documentation if the therapists don't clearly indicate their scope of practice and how their participation of the co-treatment relates to the patient's physical therapy, occupational therapy or speech-language therapy goals and plan of care.
On the other hand, this can be a great tool to allow us better flexibility since our current operational procedures require more one-to-one treatment plans. It's also very helpful for patients with behavioral issues. As my picture indicates, I am a white woman. I once treated an African-American gentleman diagnosed with dementia with Lewey-Bodies (a fast-progressing Alzheimer's disease affecting a younger population). For whatever reason, this patient felt I was his long-lost daughter and we developed a strong rapport.
His African-American wife brought in pictures of his entirely African-American family, and found it amusing he had made this assumption. Also, for reasons unexplained, this patient would participate in therapy only if I was directly working with him. Through co-treatment approaches of PT and OT, we were able to rehabilitate this gentleman from dependency with transfers, mobility, and activities of daily living to an almost supervision level in all areas.
I'll never forget this patient, or our treatment approaches, but I wish the current regulations on co-treatment billing were in effect a few years ago.
Shelly Mesure ("Measure"), MS, OTR/L, is the president and owner of A Mesured Solution Inc., a rehabilitation management consultancy with clients nationwide. A former corporate and program director for major long-term care providers, she is a much sought after speaker and writer on therapy and reimbursement issues.