Blog
Court-Ordered vs Attorney-Issued Subpoenas: What Outpatient Therapy Practices Need to Know (Release of Records Series – Part 3)
Outpatient therapy clinics frequently receive requests for medical records, including those without patient authorization. In the first two articles of this four-part series of the BCMS Blog, we explored requests from attorneys and those supported by “satisfactory...
Release of Records: Satisfactory Assurances for Permitted Uses & Disclosures of PHI (2 of 4)
Satisfactory Assurances for Permitted Uses & Disclosures of PHI In Part 1 of this series, we explored the release of records when attorneys request them. In this second installment, we dive deeper into scenarios where your clinic may receive requests for medical...
Release of Records to an Attorney: Record Release Series (1 of 4)
Navigating Record Release Requests: A Guide for Outpatient Therapy Practices For managers and owners of outpatient therapy practices, managing mail is often a low priority due to the demands of patient care and other matters; however, great care should be taken to...
Non-enrolled Therapist Supervision Under Medicare and Sign-offs Explained
Learn who can legally sign off on Medicare therapy treatments. Understand the rules for enrolled vs. non-enrolled therapists and avoid compliance risks.
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...