Is this billable time?

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Shelly Mesure, MS, OTR/L
Shelly Mesure, MS, OTR/L

The title sounds like an obvious question, but I can guarantee that the majority of therapists have under billed at some point in their career. So, I ask: What is billable time?

Let's start from the regulatory point of view: Billable time is providing medically necessary skilled physical therapy, occupational therapy or speech language pathologist services that directly relate to the patient's individual plan of care, while the resident is within line-of-sight.

Sounds easy enough, right? So let's take a quiz.

Is this scenario justify billable time?:

1. A resident is performing PT, OT, or SLP treatment activities and the therapist leaves the room to go to the office to document and is no longer within line-of-sight of this resident.

2. The therapist completes point-of-service documentation on a clipboard or laptop while sitting within line-of-sightof the resident performing skilled activities.

3. The POA, power-of-attorney, calls the rehab department to ask the therapist for a status update; the resident is currently in the therapy gym and is kept within line-of-sight during this phone call.

4. The POA calls the rehab department to ask the therapist for a status update; the resident has returned to his or her room and is no longer in the gym; the therapist spends 15 minutes on the phone call.

5. The OT rehab manager is attending a care plan and/or discharge meeting with the resident present; the resident is only on physical therapy and is not receiving OT at this time.

6. The PT rehab manager is attending a care plan and/or discharge meeting without the resident present; the meeting lasts 15 minutes, but the family is on the conference call.

7. The OT rehab manager is attending a care plan and/or discharge meeting with the resident present; the resident is currently receiving PT and OT services at this time. The meeting lasts 15 minutes.

Here are the answers: 1) No, 2) Yes, 3) Yes, 4) No, 5) No, 6) No, 7) Yes.

How did you do? Let's discuss the scenarios …

Questions 1 and 2 relate to providing direct point-of-service documentation; the entire purpose of POS documentation is to perform non-billable tasks (such as documentation) during billable tasks (such as active treatment time with a patient).  If a therapist does not provide this POS documentation within direct line-of-sight of their patient, it no longer qualifies as billable time.

Questions 3 and 4 relate to family education. We are constantly updating family and caregivers of the resident's status, current prognosis and upcoming discharge plans. Often times this happens as we walk down a hallway and are asked to speak with a family member who is currently visiting a loved one. As long as the conversation directly relates to the patient's plan of care and discharge goals, and the resident is kept within line-of-sight, it becomes billable time. It's then the therapist's responsibility to include this in documentation and billing for the day's total treatment time.

Lastly, questions 5, 6 and 7 relate to the therapist's time spent in meetings (such as care plan or discharge meetings). If the patient is actively on the rehab manager's discipline, and the patient is attending the meeting, the portion of the therapist's discussion can be considered patient/caregiver education and becomes billable time. In this scenario, I do not recommend billing for the entire meeting length. However, it becomes the responsibility of the therapist to determine the amount of time spent with direct interaction discussing therapy goals and outcomes.

As you can see, there are many situations when we often “forget” or fail to bill all of our billable treatment time. In an environment where the Centers for Medicare & Medicaid Services is continually finding ways to decrease our reimbursable therapy minutes, it requires therapists and assistants to be extra diligent when billing for all treatment time allowable.

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.



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Rehab Realities is written by Renee Kinder, MS, CCC-SLP, RAC-CT.  She currently serves as Director of Clinical Education for Encore Rehabilitation and acts as editor of Perspectives on Gerontology, a publication of the American Speech Language Hearing Association.