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Outpatient therapy: Myths and risks

Nancy J. Beckley ( is President of Nancy Beckley & Associates LLC in Milwaukee, WI.

Outpatient therapy, particularly physical therapy, continues to be an area of concern for providers, regulators, investigators, adjudicators, and legislators. With Centers for Medicare & Medicaid Services (CMS) having entered an enlightened era of reducing provider burden, outpatient therapy providers are not necessarily “feeling the love,” save the elimination of functional limitation reporting (FLR) for dates after 1/1/2019. Physical therapy has continually been a topic on the OIG’s Work Plan; therapy over the $2,040 annual therapy threshold is subject to CMS medical necessity review; data analytics are driving CMS therapy reviews under the Targeted Probe and Educate (TPE) program; and the Health and Human Services Office of Inspector General (OIG) and the Department of Justice, including various United States Attorney’s offices, seem to keep therapy on the top of their radar.

With all the reviews, reports, and whistleblower activity, it seems therapy providers would revisit and update a compliance risk assessment, incorporate these case studies in compliance education and training, or at the very least, take to late night reading and studying the transparently available CMS rules and policy. Providers often look to social media groups to find answers to questions on key areas of therapy risk. More often than not, providers accept answers that are incorrect, out-of-date, or not applicable for one reason or another. Providers that have compliance programs and hotlines report that clinicians ask questions about basic therapy documentation coding and billing requirements, often identifying therapy CEU courses and social media groups as the source of inaccurate and misleading information.

This article identifies a few of the top therapy myths and inaccurate information that gains a life of its own in social media groups. Each of these identified areas of concern also may pose an area of risk to be addressed in the provider’s compliance program and risk assessment.

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