Under the Affordable Care Act (ACA) physical therapists in private practice were elevated from a “low” risk in the enrollment category to a “moderate” risk. Physical Therapist in private practice were enrolled prior to 3/25/2011 are now required to revalidate their information. As part of the revalidation process a site visit will be performed to ensure compliance with Medicare standards. Additionally for physical therapists changing locations or reassigning their benefits to another practice a site visit will also take place. In Transmittal 404 to the Medicare Program Integrity Manual CMS offer the following important update for physical therapists in private practice. The following is the information provided on site visits:
…. the contractor shall perform site visits in accordance with the following:
- Initial application – If a physical therapist or physical therapist group submits an initial application, the contractor shall conduct a site visit prior to the contractor’s final decision regarding the application.
- Revalidation – If a physical therapist or physical therapist group submits a revalidation application, the contractor shall conduct a site visit prior to making a final decision regarding the application.
- New location – If a physical therapist or physical therapist group submits an application to add a new practice location, the contractor shall conduct a site visit of the new location prior to making a final decision.
- Reactivation – If a physical therapist or physical therapist group submits a reactivation application, the contractor shall conduct a site visit prior to making a final decision.
In this transmittal, CMS also instructs the contractors to do the following during the site visit:
In section 2A of the Form CMS-855B application, physical and occupational therapy groups are denoted as “Physical/Occupational Therapy Group(s) in Private Practice.” If a supplier that checks this box in section 2A is exclusively an occupational therapy group in private practice – that is, there are no physical therapists in the group – the contractor shall process the application using the procedures in the “limited” screening category. No site visit is necessary. If there is at least one physical therapist in the group, the application shall be processed using the procedures in the “moderate” screening category. A site visit is required.
If an entity is enrolled as a physician practice and employs a physical therapist (PT) within the practice, the practice falls within the “limited” screening category. This is because the entity is enrolled as a physician practice, not a physical therapy group in private practice.
The site visit requirement applies to all physical therapists, including those who are reassigning their benefits to a physical therapy group practice or multi-specialty group practice. This may mean that the contractor will need to perform site visits at the same group practice as additional PTs join that group.
If a newly-enrolling physical therapist lists several practice locations, the contractor has the discretion to decide the location at which it will perform the required site visit.
A site visit will be required when a physical therapist submits an application for initial enrollment and reassignment of benefits (Form CMS-855I and Form CMS-855R). However, a site visit is not required for an enrolled physical therapist who is reassigning his or her benefits only (Form CMS-855R).
If the physical therapist’s practice location is his or her home address and it exclusively performs services in patients’ homes, nursing homes, etc., no site visit is necessary.
Do you have a policy to handle site visits and investigations?