CMS Updates May 2008:  On May 7th, CMS released Transmittal 88, Change request 5921: Therapy Personnel Qualifications and Policies Effective January 1st, 2008.  With this transmittal CMS changes the IOM Manual Pub. 100-02, Chapter 15, Sections 220 and 230 to reflect the policies identified in the November Final Rule for the Physicians Fee Schedule.
 
90-Day Certification:  The 90-day MD re-certification for Medicare Part B Therapy claims is now official.  However, the initial certification is required within 30 days. 
 
Per CMS the frequency or duration of the treatment may not be used alone to determine medical necessity, but they should be considered with other factors such as condition, progress, and treatment type to provide the most effective and efficient means to achieve the patient's goals. For example, better outcomes at less cost may sometimes be achieved by skilled treatment once or twice weekly to assess and modify the plan with independent exercise by the patient between skilled visits. Continued progress is a sign that treatment is effective and may indicate that skilled treatment should be continued.
 
CMS instructs the Administrative Contractors that there is no restriction on the way duration of treatment or a certification interval may be expressed. Variations may include e.g., calendar days, number of treatment sessions, or number of weeks of treatment. Contractors shall interpret the certification interval using the longest of the durations in the plan. As long as the physician approves the plan and the plan does not extend more than 90 calendar days from the first treatment day of that plan, the certification is acceptable for either the number of treatments, the number of weeks, or the number of calendar days that represent the longest interpretation of the duration of treatment. For example, if a plan is written and certified for 3x/week x 4 weeks and the patient receives treatment 3x/week for 3 weeks but is absent the 4th week, then the planned 4th week of treatment is still certified if it is delivered later, assuming the plan remains appropriate and the treatment remains skilled and necessary. Or, under the same circumstances the plan is still certified when it includes treatment 4 times the first week and 2 times the last week. A reasonable amount of variation in the plan is acceptable.

HARMONY UNIVERSITY