Pennsylvania providers have reported receiving demand letters on untimed codes for therapy from DCS, the Region A RAC covering the Northeast, wrote Nancy Beckley, president of Bloomingdale Consulting Group, in the RAC Monitor.
"A potential vulnerability may exist if certain codes are billed for more than one unit," DCS reported. DCS referred to CMS Transmittal 1019, dated Aug. 3, 2006, which said codes in a chart identifying therapy codes "may be billed no more than once per provider, per discipline, per date of service, per patient."
Ms. Beckley confirmed therapy can only be billed for a unit of service, regardless of the time spent on the encounter. However, she wrote there is no prohibition against billing two separate and distinct untimed codes, such as for physical therapy evaluation on the same day as a speech-language pathology evaluation. NCCI edits also do not prohibit billing these codes in pairs, she stated. "But it would appear that DCS has interpreted this practice as one plus one equals two, and therefore is sending demand letters to providers," she wrote.
Read the RAC Monitor report on the Region A RAC.
Read more coverage on RACs:
- 10 Tips on Improving RAC Readiness From Kaiser's RAC Expert
- 18 Findings from the Latest AHA Survey on RAC Activity
- 6 RAC Issues For Hospitals in 2011
"A potential vulnerability may exist if certain codes are billed for more than one unit," DCS reported. DCS referred to CMS Transmittal 1019, dated Aug. 3, 2006, which said codes in a chart identifying therapy codes "may be billed no more than once per provider, per discipline, per date of service, per patient."
Ms. Beckley confirmed therapy can only be billed for a unit of service, regardless of the time spent on the encounter. However, she wrote there is no prohibition against billing two separate and distinct untimed codes, such as for physical therapy evaluation on the same day as a speech-language pathology evaluation. NCCI edits also do not prohibit billing these codes in pairs, she stated. "But it would appear that DCS has interpreted this practice as one plus one equals two, and therefore is sending demand letters to providers," she wrote.
Read the RAC Monitor report on the Region A RAC.
Read more coverage on RACs:
- 10 Tips on Improving RAC Readiness From Kaiser's RAC Expert
- 18 Findings from the Latest AHA Survey on RAC Activity
- 6 RAC Issues For Hospitals in 2011