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Are You Running Your Private Practice Naked?
Are You Running Your Private Practice Naked? Compliance for Outpatient Therapy Providers ... the requirement that private practitioners often put in the back of the closet. When regulators come to your door, do you want to be naked...i.e., without a Compliance...
Selecting the Right Clinical Auditor | BCMS Compliance Blog
Selecting the Right Clinical Auditor for Your Outpatient Therapy Practice In today’s outpatient therapy landscape, the rapid adoption of technology, including cutting-edge AI services, is transforming practice operations. Among the least favored responsibilities for...
CMS Phishing Fax Fraud Alert
What is Phishing? The U.S. Department of Health and Human Services (HHS), through its Office for Civil Rights (OCR), defines phishing as a sophisticated cyber-attack designed to deceive individuals into disclosing sensitive information through electronic...
AI and the Battle Between Eliminating Administrative Burden and Staying Compliant
When a patient enters a clinic suffering from debilitating pain that disrupts their ability to work, sleep, engage with family and friends, or pursue a healthy lifestyle, 'compliance' is likely not the foremost concern of the physical therapist. The therapist's...
Questions & Answers Relating to Out-of-Network Providers and Commercial Payers
This article is based on an extended and updated version of a PPS Taskforce Project that both authors participated in 2019-2021. It explicitly addresses new regulations related to balance billing, the No Surprises Act, and Good...
It Is an Emergency That You Be Prepared, Pt. 2
Shocking Variances Between Private Practice and Rehab Agencies Part Two of this Two-Part Series: Mary R. Daulong, PT, CHC, CHP In Part I of It Is an Emergency That You Be Prepared the focus was on Therapists (TPP) in Private Practice and COVID Emergency Preparedness...
CMS’ Advance Beneficiary Notice (ABN) Frequently Asked Questions
Understanding how to properly use the Medicare Advance Beneficiary Notice (ABN) is critically important because it has financial, fraud, and abuse consequences. Using it correctly could permit providers to collect monies legally that may otherwise have been left on...
It Is an Emergency That You Be Prepared, Pt. 1
Shocking Variances Between Private Practice and Rehab Agencies Part One of this Two-Part Series: Mary R. Daulong, PT, CHC, CHP As you know, a comprehensive compliance program should address all areas of vulnerability related to federal, state, and local laws...
A Medley of Frequently Asked Compliance Questions
By Mary R. Daulong, PT, CHC, CHP Question: Re-evaluation Documentation Where do I locate the required content of the Re-evaluation CPT code 97164? Answer: There are two references you should use to assist you in your re-evaluation documentation and rationale for...
Congress Passes the Suspension of the Sequester Cut Through 2021
Per the APTA's News Release on April 14, 2021: Congress Passes the Suspension of the Sequester Cut Through 2021. The U.S. House of Representatives overwhelmingly approved the relief, which is expected to be signed into law by President Biden in the coming days. The...
The Administrative Burden and Mental Stress of Audits
The adage, “If momma ain’t happy, ain’t nobody happy,” is a very transferable truism and certainly can apply to working with health care auditors. Just imagine if your job were to review clinical and billing records all day long, five days a week. Can you envision the...
Frequently Asked Questions re: The Supervision of Physical Therapists and Occupational Therapy Assistants
Question: Does the telecommunication waiver for off-site (virtual) supervision of assistants apply to physical and occupational therapy private practices? Answer: Yes, virtual supervision of PTAs and OTAs absolutely applies to both physical and occupational therapy...
Medicare Claims Filing with the 3% Reduction
We cannot be certain, nor have we been promised, that Medicare Administrative Contractors will have the COVID-19 Relief Package with the new Physician Fee Schedule changes for therapy providers (~9% reduced to 3.6%) loaded in their systems to properly adjudicate...
Compliance with SBA Loans and Federal Funding – Are you at Risk?
There were a number of declarations at the end of each of the SBA loan applications that deal with compliance with various federal law such as civil rights laws, OSHA, HIPAA, etc.. Are you at risk for an Audit because you received an SBA loan or Federal Funds? When...
A Reprieve from Damaging Medicare Cuts
The legislation prevents proposed steep cuts to Medicare in 2021 by providing a one-time exemption from budget neutrality rules. That's important, because CMS is citing those constraints as the reason it's planning on cutting payment for more than three dozen...
CMS Announces Resumption of Routine Inspections/Surveys
CMS announced that it resumed surveys and inspections of all providers and suppliers on August 17, 2020. CMS had previously suspended certain routine inspections as part of its response to the coronavirus disease 2019 (COVID-19) pandemic to prioritize infection...
CMS Announces New Value-Based Payment Model For Rural Healthcare Providers
The Centers for Medicare and Medicaid Services today announced a new value-based payment model for rural healthcare providers. The Community Health Access and Rural Transformation (CHART) Model ties payment to value, increases choice and lowers costs for patients, CMS...
Medicare Physician Fee Schedule Proposed Rules – Federal Register
We have received a number of questions regarding which benefit categories HCPCS codes G2061 through G2063 fall under. In the March 31st COVID-19 IFC (85 FR 19244-19245) we established on an interim basis for the duration of the PHE for the COVID-19 pandemic that these...
HIPAA/HITECH Rules Still Apply for Physical Therapy Clinics
The Office of Civil Rights (OCR) recently handed out a $1.O4M penalty to Lifespan for a stolen laptop that was unencrypted. In this instance an employee had a work laptop stolen out of their car. Key violations that incurred the penalties included the following:...
Support for Private Physical Therapy Practices During COVID-19
During this uncertain time, Business & Clinical Management Services (BCMS) is here to support private physical therapy practices during COVID-19. The Department of Health and Human Services The Department of Health and Human Services has designated them members of...
HR Related Decisions for Physical Therapy Owners During COVID-19
We know it has been challenging to navigate all the staffing and HR related decisions for physical therapy owners during the COVID-19 pandemic. The information below is designed to explain options and enhance your decision-making process. The data is current as of...
Human Resources Compliance: Frequently Asked Questions
Q: Can Physical Therapist Assistant be classified as exempt employees? A: No, based on just a clinical position description. Physical Therapist Assistants, without additional job duties, usually do not meet the job criteria to qualify for exempt status as defined by...
2020 Physician Fee Schedule Proposed by CMS – Call To Action
As promised, we have reviewed the 2020 Physician Fee Schedule proposed by CMS. There are many complexities that we must study before we can give you all of the details. In the meantime, please consider reviewing the items (via links) listed below so you can have the...
Direct Access in Texas for Physical Therapy
The wait for Direct Access in Texas for physical therapy is nearly over (this means treatment with out referral)! The Texas Board of Physical Therapy Examiners has approved a draft of the proposed Rules that will govern the new provisions for Direct Access in the...
Regulatory Compliance Applies to More Than Medicare
When we talk about compliance the first thing that comes to mind is Medicare. But Medicare is just the tip of the iceberg. There are so many regulations that healthcare providers must be aware of and comply with so let’s just start with a fundamental law; the...