Q: What is my agency's responsibilities if a Medicare patient is receiving outpatient PT for whirlpool while we are providing other services (nursing and aide) in the home? I know we have to pay for these services, but what else do we do? Do we have to obtain a baseline PT eval in the home by our own therapist and have our own therapist obtain orders? Or is it sufficient to have the outpatient department take care of all this, and send us therapy notes for each visit?
A: If this Medicare patient is receiving outpatient whirlpool while under an open home health plan of care, the outpatient therapist IS "your own therapist". They are treating your patient on behalf of your agency and providing a home care therapy visit that -due to a special equipment need- is occurring in an outpatient setting. They should be working as a direct employee, or a contracted provider under arrangement with your agency. All the same requirements would exist for this therapist as previously existed for any contracted provider you utilized to provide services. Therefore, it would not be necessary to send out another PT to the patient's home to establish a baseline evaluation, unless there was a specific need to do so (i.e., evaluate the home setting or observe the patient's function in the home). If your policies allow contract providers to obtain orders, then the orders obtained by the outpatient therapist, and maintained by your agency, would suffice. Your medical record should contain all the same documentation for each outpatient visit that would be required if the visit was conducted in the home (including 15 minute incremental visit time). Additionally, you should ensure that the care provided in the outpatient setting complies with the home health COPs and the HIM-11 guidelines. For instance, in the outpatient setting, a therapist may be allowed to utilize a therapist assistant or a therapy aide to assist with therapy treatments. Care provided by a therapy aide is not considered a therapy visit/service under the home health COPs or the HIM-11 coverage criteria, and would therefore NOT be considered a covered and billable service under the home care benefit. Your agency is responsible for the clinical decision making and quality of care issued for the home care patient by the outpatient provider, and the agency will be held accountable for denials of coverage for services delivered as home health services by outpatient therapy providers.