Page 202 - Medicare Benefit Policy Manual

Progress Reports for Services Billed Incident to a Physician’s Service. The policy for
incident to services requires, for example, the physician’s initial service, direct
supervision of therapy services, and subsequent services of a frequency which reflect
his/her active participation in and management of the course of treatment (see section
60.1B of this chapter. Also, see the billing requirements for services incident to a
physician in Pub. 100-04, chapter 26, Items 17, 19, 24, and 31.) Therefore, supervision
and reporting requirements for supervising physician/NPPs supervising staff are the same
as those for PTs and OTs supervising PTAs and OTAs with certain exceptions noted
below.

When a therapy service is provided by a therapist, supervised by a physician/NPP and
billed incident to the services of the physician/NPP, the progress report shall be written
and signed by the therapist who provides the services.

When the services incident to a physician are provided by qualified personnel who are
not therapists, the ordering or supervising physician/NPP must personally provide at least
one treatment session during each progress report period and sign the progress report.

Documenting Clinician Participation in Treatment in the Progress Report. Verification of
the clinician’s required participation in treatment during the progress report period shall
be documented by the clinician’s signature on the treatment note and/or on the progress
report. When unexpected discontinuation of treatment occurs, contractors shall not
require a clinician’s participation in treatment for the incomplete reporting period.

The Discharge Note (or Discharge Summary) is required for each episode of outpatient
treatment. In provider settings where the physician/NPP writes a discharge summary and
the discharge documentation meets the requirements of the provider setting, a separate
discharge note written by a therapist is not required. The discharge note shall be a
progress report written by a clinician, and shall cover the reporting period from the last
progress report to the date of discharge. In the case of a discharge unanticipated in the
plan or previous progress report, the clinician may base any judgments required to write
the report on the treatment notes and verbal reports of the assistant or qualified personnel.

In the case of a discharge anticipated within 3 treatment days of the progress report, the
clinician may provide objective goals which, when met, will authorize the assistant or
qualified personnel to discharge the patient. In that case, the clinician should verify that
the services provided prior to discharge continued to require the skills of a therapist, and
services were provided or supervised by a clinician. The discharge note shall include all
treatment provided since the last progress report and indicate that the therapist reviewed
the notes and agrees to the discharge.

At the discretion of the clinician, the discharge note may include additional information;
for example, it may summarize the entire episode of treatment, or justify services that
may have extended beyond those usually expected for the patient’s condition. Clinicians
should consider the discharge note the last opportunity to justify the medical necessity of
the entire treatment episode in case the record is reviewed. The record should be