On December 29, 2006, the Centers for Medicare & Medicaid
Services (CMS) issued two new transmittals, changing transmittals
that contain important Medicare outpatient therapy policy changes.
Both transmittals were published on December 29; became effective
on January 1, 2007; and are to be implemented on or before January
29.
Transmittal 1145 contains changes to the cap exception
process. Most notably, it eliminates the manual process for obtaining
an exception to the cap. All services that require exceptions to caps
shall be processed using the automatic process and should be made
in the form of a KX modifier added to claim lines.
- The KX modifier
is used to indicate that the clinician attests that services are medically
necessary and justification is documented in the medical record. Transmittal
1145 also contains an updated list of conditions or complexities represented
by ICD-9 codes that may be automatically excepted from the cap. Although
clinicians may use the automatic exception process for beneficiaries
who do not have a condition or complexity on the list, their documentation
must then provide sufficient justification for excepting the patient
from the cap.
Transmittal 63 requires practitioners to include in
their documentation of evaluations either the results of a specified
performance measure tool or an explanation of certain factors. Specifically,
the practitioner may report the results of one of the following measurement
tools: the National Outcomes Measurement System (NOMS) by the American
Speech-Language-Hearing Association; the Patient Inquiry™ by
Focus on Therapeutic Outcomes, Inc. (FOTO); the Activity Measure for
Post-Acute Care (AM-PAC); or the Outpatient Physical Therapy Improvement
in Movement Assessment Log (OPTIMAL) by Cedaron, through the American
Physical Therapy Association.
If the practitioner chooses to not record
the results of one of those four instruments, then the documentation
must contain information
- supporting illness severity or complexity,
- supporting medical care prior to the current episode,
- required
to indicate beneficiary health related to quality of life,
- required
to indicate beneficiary social support, and
- required to indicate
objective measurable beneficiary physical functioning.
Transmittal 63 also contains additional policy clarifications
and reiterates CMS' policies concerning billing for group outpatient
therapy and for the services of therapy students in outpatient settings.
Update 1/03/2007
Mary Hennigan
Executive Director |
