Page 176 - Medicare Benefit Policy Manual

plan, which is described below, is not the same as certifying the plan, which is described
in §§220.1.1 and 220.1.3

Outpatient therapy services shall be furnished under a plan established by:

• A physician/NPP (consultation with the treating physical therapist,
occupational therapist, or speech-language pathologist is recommended.
Only a physician may establish a plan of care in a CORF;

• The physical therapist who will provide the physical therapy services;

• The occupational therapist who will provide the occupational therapy
services; or

• The speech-language pathologist who will provide the speech-language
pathology services.

The plan may be entered into the patient’s therapy record either by the person who
established the plan or by the provider’s or supplier’s staff when they make a written
record of that person’s oral orders before treatment is begun.

Treatment under a Plan. The evaluation and treatment may occur and are both billable
either on the same day or at subsequent visits. It is appropriate that treatment begins
when a plan is established.

Therapy may be initiated by qualified professionals or qualified personnel based on a
dictated plan. Treatment may begin before the plan is committed to writing only if the
treatment is performed or supervised by the same clinician who establishes the plan.
Payment for services provided before a plan is established may be denied.

Two Plans. It is acceptable to treat under two separate plans of care when different
physician’s/NPP’s refer a patient for different conditions. It is also acceptable to
combine the plans of care into one plan covering both conditions if one or the other
referring physician/NPP is willing to certify the plan for both conditions. The treatment
notes continue to require timed code treatment minutes and total treatment time and need
not be separated by plan. Progress reports should be combined if it is possible to make
clear that the goals for each plan are addressed. Separate progress reports referencing
each plan of care may also be written, at the discretion of the treating clinician, or at the
request of the certifying physician/NPP, but shall not be required by contractors.

B. Contents of Plan (See §220.1.3 for certifying the plan.)

The plan of care shall contain, at minimum, the following information as required by
regulation (42CFR424.24, 410.61, and 410.105(c) (for CORFs)). (See §220.3 for further
documentation requirements):