January 28, 2020

Billing And Compliance Update 2020 With Rick Gawenda

PTO 81 | Billing And Compliance Update

 

It's not often that we get THE expert in any given topic on the podcast, but today I believe that we can say that. Rick Gawenda, PT has joined us in the Club to talk about all the changes that have come as well as what we can expect over the next couple of years. Issues related to billing and compliance are consistently ongoing and changing so it's imperative that we rely on trusted resources like Rick to keep us up-to-date. In today's episode, host Nathan Shields and Rick talk about the changes and announcements that have recently come from Medicare, and some of the commercial payors recently and how they'll affect us over the next few years. Whether it's questions about reimbursement, PTAs, or Dry Needling, Rick has the (current, as of January 2020) answers.

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Listen to the podcast here:

Billing And Compliance Update 2020 With Rick Gawenda

I am excited to bring on my next guest, Rick Gawenda. If you don't know about Rick, he is a resource and what I consider the source when it comes to knowing exactly what some of the changes are occurring in the physical therapy industry and how they affect us, especially as outpatient owners. I ask him all the questions because we've had some Earth-shaking announcements come down the pipe from Medicare and some of the commercial payers in regards to changes of payment from 2020 to 2022. I asked him other questions and got into it quite a bit regarding some of the changes to CPT codes as well. We cover a lot of ground, so let's get right to it.

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I've got Rick Gawenda. I'm excited to bring him on because Rick is what I believe the foremost authority on billing and coding for physical therapists and in the physical therapy industry. He is the Founder and President of Gawenda Seminars & Consulting. I'm sure you have come across his information in the past. I'm excited to talk about some of the changes that are going on and things that we need to be aware of as physical therapy owners. First of all, thank you, Rick, for coming on. I appreciate it.

Thank you, Nathan, for having me.

For those of us who don't know a lot about you and your history, do you mind sharing your professional story and what got you to where you are?

I'm considered one of those old-time physical therapists. I graduated back in 1991 with a Bachelor's of Science in Physical Therapy. I grew up in the hospital setting and in the acute care setting. After about 6 or 7 years of doing that, as many of your readers, if they grew up in a hospital setting or even a type of practice setting, they get asked the question of, “You show up all the time. You're punctual. You don't call in sick. Do you want to be a manager of one of the departments we run in an offsite clinic?” I was promoted to one of the offsite clinics that the hospital-owned plus the hospital contracts. I did that. Probably like many hospitals, you work with the billing department, the accounts payable department and you're asking them, “How are we doing?” They come back, “Everything's going good.” “Any denials?” “No, everything's fine.” You hear the same story month after month. All of a sudden, one day, when 100% of Medicare review for physical therapy. It's one of those things that, “It wasn't going well.” “Every month, you told me it was going well.” It wasn't an issue to them until we got put on a 100% review.

Don't worry about how recent changes may affect you until you know your numbers. Then you can take appropriate action. Click To Tweet

Nobody knew what to do at the time. I can't remember if my director asked me if I volunteered to learn about the billing issues, the coding, the denials, and documentation, but it took me about 1.5 to 2 years to get us off this 100% prepayment review. It was a long time, but I fell in love with it in a weird sense of the way. In the early 2000s, Listserv became popular on the internet. I joined a couple of those and was those silent people that read everything, so-called information, but would not respond. After doing that for a while, I felt comfortable and started answering some questions and then somebody must've thought I was smart because then they asked if I wanted to do a live speaking engagement for their organization. It then led to a book deal where I was able to write two books. That started me to start my company, Gawenda Seminars & Consulting, back in 2003. Until Christmas of ‘09, at that time I had moved into Hospital Administration Management. I was doing both, Hospital Administration Management from 2003 to 2009 and on weekends would speak around the country, and I finally left the hospital on Christmas of 2009. For years, I focused on the country on compliance, productivity scheduling. This decided the physical, occupational and speech therapy.

PTO 81 | Billing And Compliance Update
Billing And Compliance Update: An owner needs to set their calendar up in October and November every year to check in on what's happening.

 

It's refreshing to have someone like you that not only has a physical therapy background, but has niched their billing, training, and consultations to the therapy space because I don't think there's a lot of you out there. It's refreshing to have a resource like you out there in the PT industry. It's great to have you.

Being a PT helped, spending many years in a hospital setting has helped me with the hospital clients, but my wife, I, and another business partner have owned two private practices here. I get both ends of it. When things go along with the Medicare program or other insurance companies, not only do I see it as a consulting side, but we also feel it on the business side like many of your readers and followers that read this blog. When people say, “Rick doesn't have to deal with what I have to deal with. Yes, Rick does have to deal with what you deal with.” We do it with two clinics here in California.

That's good to know because you have some boots on the ground knowledge of what's going on. What is going on? What are some of the things that might be confusing or concerning regarding some of the changes that are happening both in 2020 and 2021 that you're addressing?

The two biggest things are the new CQ, a modifier for physical therapist assistants, a CO modifier for occupational therapy assistants that the traditional Medicare program implemented on January 1, 2020. We also saw that Humana announced in December 2019 that they are implementing the CQ and CO modifier in January 2020 as well in their Humana, Medicare Advantage plans as well as their commercial plans. Knowing that payment will not be affected until 2022. If that CQ modifiers on a CPT code or that CO modifier for OT is on an OT CPT code, those services are going to be paid at 85% of the same service done by a therapist out to CQ/CO. When this was announced by CMS in 2018, I had been preaching that whenever Medicare does something stupid, other payers are sure to follow.

As you see, Humana jumped on the bandwagon and they're going to implement that same reduction in 2022 to my opinion only. I think you're going to see Aetna and Cigna and maybe some of the Blue Crosses and other payers also knew that and start to reduce payment in 2022 if those services are done by an assistant. That's one reason for the readers to follow you and stay tuned with it. That's why I think advocacy is important and supporting APTA and AOTA to try to prevent these things from happening on the Medicare front because a lot of payers follow what the Medicare program does. That's the number one issue. The number two is we see that there were some new NCCI edits. It became effective on January 1, 2020. If you do therapeutic activities and a PT or OT evaluation the same day, Medicare won't pay for the evaluation CPT code. My hope is that depending on when your readers read this blog, we do expect that to get changed by CMS. We're waiting to see if they're going to remove this edit because my feeling as a therapist are we should be able to do an evaluation and also treat on the same day. Why they picked out that CPT code? Why they picked it out is one of the better-paying CPT codes under the Medicare program.

I've seen that concern on social media quite a bit about 97530 not getting paid out or one of them not getting paid on that initial evaluation.

The evaluation is not getting paid.

The eval is not getting paid. That's crazy.

Other payers that use these edits are also doing the same thing. This is a CMS thing, but other payers that use these edits do the same thing. When Medicare does something stupid, other payers are sure to follow, another example. We do think that one is going to get either removed and/or they'll still have the edit but it will allow for the use of modifier 59 so you can get paid for both activities and evaluations on the same day.

That hasn't happened yet. If it does go into effect, if it does get reversed, we can optimistically hope that it changes in 2021 or prior to that.

My opinion only, if it gets changed, it's going to happen one of two ways. The next version of NCCI comes out on April 1st of 2020. They get updated every quarter. January 1, April 1, July 1 at 12:01. My opinion at the latest, I'm thinking April 1 with version 26.1. There is precedence though of them updating it because the new one started January 1. There has been precedence when they have changed the edits in that three-month period. They've gone back and done a revision and made it retroactive to the start of the version. There's that possibility as well that the APTA and AOTA are working with CMS on this and waiting to hear something.

It's odd because we used to worry about the cap if it was going to change and then the appeal to get over the cap. Now it's much more. It's going crazy.

Because the other one that was also in effect on January 1st is if you build a PT/OT eval in myotherapy the same day. Myotherapy needs modifier 59 placed on it and Medicare won't pay for the eval in myotherapy, but you have to use modifier 59. If you don't use modifier 59 on the CPT code, you're only going to get paid for the eval and not for myotherapy. Those were a couple of unexpected changes that came out of nowhere.

Once Medicare does it, that gives license to all the other commercial players to do the same. Click To Tweet

The 15% reduction in payment, that happens in 2021 for Medicare.

A court for the CQ/CO modifier that will go in effect January 1, 2022. We have a couple of years to practice in 2020 and 2021 getting familiar with the CQ/CO modifier, but they'll give CMS and Humana a couple of years’ worth of data to see exactly how much therapy is being done either in or in part by an assistant compared to it all being done by a therapist.

I'm glad you clarified because I assumed it would be in 2021. I've had friends that are saying, “It started now.”

It's both. The modifier started, but it won't impact payments for 2022.

The 8% reduction then also begins in 2021.

That's what's proposed. If you look at the final, both the proposed rule that came out on July 29th of 2019, the fine would have come out on November 1, 2019. CMS is proposing an 8% reduction to CPT codes go by PT and OT in 2021. That's because they're increased in payment for other CPT codes. Whenever they increase payment for some CPT codes, they have to take it from somewhere else. It has to be budget neutral. We don't know what CPT codes they're proposing to reduce. We won't know that until they release the proposed rule in July of 2020 and then we'll get the comment and all that. I have been paying attention to APTA, Twitter and Facebook. APTA has been meeting with CMS already about this. They're working with the Congress people, whether it's the representative or the senator.

There are template letters out there that ATG members could complete and send in. Those letters do make a difference, even though they're a template. You take the time to fill it out, put it in a couple of sentences unique about yourself, sign and submit. It makes a huge difference. People think, “It's a template letter.” They look at the number of letters they're receiving and the number of comments they're receiving. You could have 10,000 templates or six unique, they care more about the 10,000 that took the time to send it in completely. I would encourage your followers to go to APTA.org and find that template and vet those comments. It does make a difference.

It's worth the time that you've got to do something. This call to action is necessary because it's simply a trend. What you're showing is once Medicare does it, that gives license to all the other commercial payers to do the same.

We saw that with functional limitation reporting back in 2013 and the G codes that Medicare no longer requires. Once Medicare implements that functional limitation reporting, you saw worker comp carriers do it. You saw Aetna do it. You saw some other payers do that with the multiple procedure payment reduction policy. Aetna jumped on the bandwagon. United Healthcare and Humana jumped on the bandwagon. It goes back to the same thing I keep saying, when Medicare does something stupid in the opinion of us, other payers are sure to follow. I think we see the history of that with the functional limitation reporting, with the multiple procedure payment reduction policy and you're going to see it now as the CQ/CO modifiers.

PTO 81 | Billing And Compliance Update
Billing And Compliance Update: You want to know your payer mix: what percentage are Medicare versus Humana and other large payers.

 

We'd like to think that maybe Medicare can do some of these things in a vacuum and hope and pray that the commercial providers don't do the same thing, but inevitably it's going to happen unless we do something about it. It's worth our time even if we are turning full time to go to the APTA.org website and find that template and send it in. I like your advice. It is simply about the sheer number and volume of communication that they get, letters, emails that they get and not simply the uniqueness of our letters.

To give you a follow-up of some positive on that with these new CQ/CO modifiers, CMS was going to implement some new documentation requirements that PT and OT are going to have to document in the medical record. Why they use CQ? Why did it not use CQ? CMS will see about 10,000 comments from physical therapist assistants fighting against that and because of that, they chose not to implement those new documentation requirements. This is one example of things that we put one on by submitting thousands of comments. That seemed large for the thing that's going to be important with this key percent proposed reduction once the proposed rule comes out. It's important with the new NCCI with therapeutic activities and the PT eval code. There’s a template letter there. It makes a difference.

That's probably 15 to 20 minutes of an owner or provider's time to go to the APTA website and TOPS and send it there. I'm sure APTA already has the representatives listed for your area as well.

It's not even representative. It's a comment to CMS.

All directly to CMS.

It gives you the email address. It's easy to do.

That's instructional to me. I'm assuming we're talking to our representatives and whatnot, but this goes straight to CMS and cuts those middlemen.

What I can do for you is send you the link and we can figure out a way to get that to your followers.

Thank you so much. We're looking at many of the current changes that are going on. Looking over your experience especially in the past several years that you've been solely doing this. Are there common questions that come up from providers still over the course of the last few years that you have to address?

At the beginning of every year, and unfortunately, therapists and assistants don't know if the changes that are in effect because we know about the new CPT codes or this new CQ/CO modifier or these new NCCIs. We sometimes know months in advance. Sometimes you may only know about a month in advance. A lot of the questions I receive over the last several years, a lot of it in January of every year is, “When did this start?” When did this come out? When did we know about it? I think that the topic changes a lot of times every January. Overall, I think if you look at the last few years, there's still confusion out there about the therapy threshold. People still tend to call it a therapy cap. There is no therapy cap. It's a therapy threshold. People are still worried about going. In 2020, it's $2,080 physical therapy and speech therapy combined and separate $2,080 OT.

People are still worried about going over the $2,080. If you are familiar with the targeted medical review of the $3,000, people think that's a second threshold. There's one threshold and there’s no special documentation required for that to have special documentation. I have to submit something to Medicare. People don't understand that therapy above the threshold and how you document, how you charge, how you bill is the same as below the therapy threshold. We've got new dry needling CPT codes, the Medicare program not to pay for the dry needling CPT codes. I get a lot of questions about dry needling and how to charge Medicare patients for dry needling.

For some of my owners, what is your recommendation regarding the dry needling CPT codes? Can they charge cash for that dry needling care that they provide a Medicare patient?

As we are talking in 2020, we'd have to say that because things can change. The Medicare program has labeled these codes as non-covered because they're non-covered, you can charge a Medicare beneficiary cash for dry needling. No ABN would be required. Advanced Beneficial Notice, a non-coverage is not required because there's a non-covered service and then you would not bill those CPT codes on the claim form. They don't show up on the claim form.

It's hard to know where Medicare is going in five or ten years. Click To Tweet

If they are paying cash, you don't claim that to Medicare.

The time you're doing the dry needling does not get added to anything else because you paid cash for that.

That’s good to know. To me, you're the only resource to stay on top of some of these changes and if necessary, an owner needs to essentially set their calendar up in October and November every year to check in on what's happening. What do you recommend? How do owners that don't have a lot of time to stay on top of the changes that are coming through?

As I go and get my sub plug answer here, this is assuming the owner does not have the time to own it, does not know which websites to go to. Number one, in bond APTA, you want to sign up for the automatic email notification, so it comes right to your inbox. You can still click on the email and look at stuff. One way that people find me is I have a website service. You go to my website, GawendaSeminars.com, you can become a gold member. There's a fee, it's $180 per year if you join, that’s good a year from now. I publish 2 or 3 articles a week about updates and changes. You get an email every Tuesday or Wednesday from me on, “Here's this article that I published this week. Here's a brief synopsis about it, click here to read the article.” The joke I make, it's like a horse in the water. I can lead you to the article. I can send you the email, but I can't make you click on the email. I can't make you read the email.

That's one of the frustrating things for me because I've got people that run to my website service and they'll email me questions that, “When did this start?” I was like, “I published an article on this a few weeks ago.” “I didn't go to your website.” That breaks my heart because people are paying for this. It's out there for you, but you're not going there. It's either the owner does it or if the donor has an office manager or front office person. I have a lot of front office people as members to my website and they're the ones that a lot of times read this stuff and then they get back to the owner, take it back to the staff and say, “Here's the latest and greatest.”

They can sign up with you and $180 is a steal, honestly. You say APTA also has automatic emails. Is that as simple as going to their website and then looking under one of their tabs?

I couldn't tell you exactly how to do it because I did it a long time ago. I'm not sure if it's you sign in to your account as a place to do it. If not, even if you can't find it, email somebody at APTA and say, “How do I sign up and have this come right to my inbox?” I get the APTA PT in Motion every Friday. If there's breaking news, emails that come out, social media, Twitter. I post a lot of stuff out there for free. If you're on Twitter, follow @APTATweets. Here's another plugin. I can do this, @KaraGainer. She works at APTA Legal, but she's out on Twitter and she posts a lot of stuff from APTA as well. There's Facebook, not much Instagram, but I would say Twitter's probably the biggest one that's posted all of my stuff. I'll put stuff out on my Facebook page as well.

Looking forward, projecting past 2021 and what we're dealing with, what do you see coming down the pipe a few years from now? Maybe it's hard to predict where Medicare is going, but 5 or 10 years from now, do you see some trends or things to be aware of in the future that could affect how we're doing things now?

This is something that I want to mention is because we do have the CQ/CO and the payment reduction coming in 2022 by Medicare. I think other payers are going to jump on this bandwagon. I think something for your followers that they need to start looking at is what percent of your patients are Medicare? What percent is Humana? What's it cost you to pay a therapist per hour? What's it cost you to pay an assistant per hour? Since this is a 15% reduction, if there's a big enough gap between what you pay a therapist per hour and an assistant per hour, maybe there's a $20 an hour gap, maybe that 15% won't hurt you as bad. Where there's only an $8 gap between what you pay a therapist and assistant per hour when you get benefits and all that. That 15% reduction could hurt you. If you only do 6% Medicare and your other 94% is more of Blue Cross, Aetna, Cigna and private payers were at the cap and they don't implement those, the CQ/CO. Can you then shift Medicare patients all seen by a therapist, personal assistant? I think they need to start looking at that because it is a reality coming in 2022. Don't wait until December of 2021 to figure out your budget and how it's going to impact you in 2022 and beyond.

I love that you said that because I always bang the drum about knowing your numbers. This is simply a report typically in your EMR regarding your payer mix. If you can't get it in your EMR, then you need to reach out to them. You want to know your payer mix and what percentage are Medicare versus Humana, the other large payers. It's probably a meeting with your CPA or whoever's doing your payroll to say, “Exactly what you said.” What am I paying for my PTs, which is my APTA? Because I think the default, once we heard that information from what I could tell on social media was, “I'm getting rid of my PTAs.” Pump the brakes. Could you possibly shift them to other patients or is it worth it to keep them on even at the 15% reduction and have them still treat patients? One question and it's a little bit detailed. I don't know if we'd know the answer. Can you have the CQ modifier for a line item in a claim that only that code gets paid the PTA rate versus the other codes that might be a PT rate?

I'll give you a couple of examples. Let's say you have a Medicare patient and the Medicare patient sees fifteen minutes of exercise by the PT. The PT gets called away or whatever for some reason and another fifteen minutes of exercise is done by the PT assistant. You get 30 minutes, we can bill two units. What you need to do is on one-line item, put one unit 97110 without CQ, so it’s 97110 GP. On the line below, one unit, 97110 GP/CQ. Another example could be the PT does say 30 minutes of manual therapy and then the assistant does 15 minutes of exercise. Same logic tune. It's 97140 GP all done by a therapist, one unit, 97110 GP/CQ, the assistant.

That's good to know because what we project will happen was simply that everything would get cut by that 15%, whereas it's only the line items. If they do see them for the entire course of the care, it's going to be cut 15%. If you're only having them do portions of the therapy, then it was not going to take you from $100 down to $85 per visit on average. It could be significantly less.

What they have to look at is because there are practices that the PT assistants carry their own schedule. They don't share patients that visit between PT and PT assistants. If they have their own schedule, in 2022, you might want to assume it stays with Medicare and Humana. If we've got any of the payers, you may want to switch those Medicare, Humana patients to being seen by a therapist. Whereby if you're in a practice where it's always a PT, PT assistant tag team and every patient that comes in. If you're going to continue to do it that way, you might see a bigger decline in your reimbursement versus switching the way you treat your patients.

PTO 81 | Billing And Compliance Update
Billing And Compliance Update: You've got to put on an owner and an admin hat that you didn't have before, and you have to know your numbers.

 

There are a lot of options to consider. If you don't know the numbers, then you're not going to be able to make some actionable changes or informed changes. The last thing you want to do is wait until July, August, November of 2021 to figure this all out.

You've brought up a great point because there are many times I had people contact me and they want me to review an insurance contract and they said, “Rick, I don't know if we should sign this contract. They were going to pay me $65 a visit.” My first question then is how much does it cost you to provide a visit? “I don't know.” I don't know if you should sign the contract or not because there are many practices that don't know their cost per visit. They don't know their income per visit. I asked for, “How many units per visit are you billing?” “I don't know.” “How many units per paid work hour are you billing?” “I don't know.” If you don't know that on a monthly basis, you can have some issues trying to figure out the CQ/CO on assistance. A lot of private practices, what I call the small mom-and-pops. It's just them. They may have 1 or 2 other therapists, but they're the ones treating patients all day. They're marketing. They're making insurance contracts, they’re probably trying to do their billing. They're trying to do everything, but they're not paying attention to the business aspect of it and where the money's going and the productivity.

It's something that I harp on quite a bit and the need to get some business training, some admin because our default is what we've been trained on for the past 20, 30 and 40 years. That is to provide physical therapy, but once you own the business the dynamic changes. You've got to put on an owner and an admin hat that you didn't have before and you have to know your numbers. It's vital to get some coaching, consulting, business training acumen somehow to give you the knowledge of what do I need to look at and guide me and help me out. Something that you provide or do you coach or consult on as well as doing billing support?

I do a lot of educational seminars and webinars. We've got the website service, but I also do a lot of phone consultations with small practices where when they have questions about can I do this, can I do that? I got more questions about the CHU modifier. I do all that and it's something else I do is what I call practice metrics where I work with small practices and we set them up on data collection. “Let's analyze your practice, where are you at?” and I ask for many pieces of information. Here's where you need to be. Here's your spreadsheet. What you got to do is fill this out every month and keep track of how you're doing. Many clinics don't set budgets. If I was to talk to your followers, if I could ask them, “How many of you have a 2020 budget?” We've got line items for advertising and rent and utilities. No offense, 90% are being nice, 90% I don't have it. It's probably higher, but they don't have it. I help clients understand their metrics and productivity and how to schedule patients and all of that.

You can actually charge a Medicare beneficiary cash for dry needling! Click To Tweet

You've come with such a great background. People need to know their numbers, however you want to stay, their stats, their Key Performance Indicators, KPIs. They need to know. Inevitably, correct me if I'm wrong, I'm trying to promote the value of having a consultant, whoever it is. When you start measuring the metrics, they inevitably start getting better. You can give them some formulas and whatnot, but once you start paying some attention to them, especially the bad ones, you start acting enough to do some benefit to him.

I've been in this for many years, so I may be in a different place with some of your followers, but we were at one point where some of your followers may be where you didn't have the money or you were concerned about the money. Whether you pay another consultant or me, I always say a reputable one knows therapy, etc. For an hour of time, if you pay them $253, whatever they charge for an hour. If you're not making that money back within a few weeks, something's wrong. Assuming there were issues to go with, something's wrong. The other thing I think why data collection is important. To have monthly data, yearly data because somewhere down the line your followers will want to sell their practice. Do you have the last 2 or 3 years of data where you can show your visits, your units, your income, your expenses? Figure out your add-backs and all of that is also going to affect your EBITDA when you go to sell. You don't want to have somebody come to you and say, “Nathan, I’m going to buy your practice. I need this and this.” You're going to spend the next few months trying to go back and do 2 to 3 years of data collection and get everything done.

They want to see it all.

Most people, when they start a private practice, my hope is, “I know when you start a private practice, your focus is on starting it but watch your end game.” My belief is your end game is you’re going to sell that practice unless you have a child coming up behind you that you may sell it to them, but you can't sell something and try to get your EBITDA and trying to multiply if you don't have the data.

It's hard to determine what it's worth if you don't have the information. It's like going out to the market saying, “I'm selling this.” They say, “How much do you want for it?” “I don't know. How much do you want to pay?” That's not a position of power you want to be in. You've answered a ton of questions and given us some great information and I appreciate it. I want to get your opinion as I look around at some of the EMRs that are better out there. Are you satisfied with the data collection that you can get and provide the billing support that you espouse, the compliance, and that stuff? Are you finding that our EMRs, in general, are doing good? Are you finding that they generally could do better?

I think the answer is yes to both of your questions. I think they are doing good. I think they can do better. It has developed so much over many years. When I say developed so much, really becoming therapy-specific. I'm not going to name companies here, but there are many good trauma record systems out there that focus solely on outpatient physical therapy, occupational therapy and also extends to speech therapy. Being that you are in as a private practice, people do believe you should be on an uptrend medical record system. You shouldn't be on that. Which one you choose, you've got to look at it from three perspectives.

You need to look at it from the front office perspective. What do they need in terms of the intake? Send out email reminders and all of that. How's that workflow for them? I think you need to look at the PT, PT assistant perspective, for example, and the documentation of how's everything flow. The backend, which I think is your practice, you are the owner of the company, you are the biller, you've done company, office manager. What financial reports can you generate? Can you break it down to each therapist, each assistant? How many units they do that a month? How many visits did they do that month? What were their gross charges that month? When you look at some of the bigger EMR companies that focus on physical therapy, I think they all do a good job.

Some to me is better in one area than another, but they can all do better. I think where they can do better is the financial reporting systems. When we got to get better on the back end, we've got to be able to give the owner, give the billing company, the office manager, whoever you delegate that to. We've got to be able to run these reports. On February 2nd, February 3rd for January, each therapist, each assistant, units, visit gross trip, how do you figure all that out? Some of the issues that we see, if an assistant makes a note, do a visit, but then the therapist signs off on it, some of the systems put that visit and units to the therapist because they signed up even though it should have gone to the assistant. How do we fix all that so we can have accurate data of what our staff is doing versus having to do it more manually?

That's where I see a lot of faults. We're on the same page. A lot of them have strengths and weaknesses that offset each other. We’re in general across the board. I wish there were better practice management capabilities. Not stuff that I need to go and fish for, but stuff that can be automatically brought to me that's pushed to me essentially. These are the key stats that you need to track or you can have your list of favorites and it automatically generates those for you on an as-needed basis or at least a monthly basis like you're talking about. Owners can steer the boat.

What I see, for example, you had five therapists at the end of a month, can I pay it? Give me a total at the end. How many is it each therapist go? How many visits? Have it do the calculation. They're averaging 3.67% units per visit. The key part is how many hours did I pay them because I want to know how productive they are. That may be something I have to add in the hours, but can an EMR system allow me to maybe add that in somehow and then do the calculation for me? I try to encrypt the system, can't do everything because I want to have all the information. If you could plug in how many hours I paid you that month because I do care about how many visits you are doing per paid day.

That's where a lot of room for growth can be. It will also make us stronger as a professional because we're talking about things on a small level to manage a small clinic. As we gather more data, generally and nationally, it makes us stronger to negotiate and puts us in a position of power when you think about it from a bigger perspective. Thank you for your time, Rick. That’s a ton of great information. If people wanted to get in touch with you, share your website, I know you have conferences coming up. How do people figure out how to get to your conferences and talk to the expert?

The easiest way is my website, GawendaSeminars.com. You can tend to take a look, see what information is out there. As a non-gold member, you see part of the article, part of the story and become a gold member. You could access the entire article. Also, on my website, I've got a tab for upcoming webinars, upcoming seminars. I'm going to be in Texas at the end of January, down in Louisiana in February, and North Carolina in March. There's also a phone number you can call me and my email address as well. You can throw stuff out and send me an email. If you need consulting services or you want to help with your practice management and all that, I can do that for you.

The seminars or courses that they might take with you, do they count towards Continuing Education Credit?

All about onsite seminars, yes. Those are usually 6.5 hours of CEU. The webinars that we do, we do not get those accredited for CEUs because they are only about 1.5 to 2 hours. Some states do accept a certificate of attendance and some states don't. It depends on the state. All the seminars we have upcoming or live seminars are approved to see and use for PT assistants, OT assistants.

I'll make sure they get there. We need to stay on top of these things. I appreciate your time.

Thank you. I appreciate it.

Have a great day.

You too. Bye.

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About Rick Gawenda

PTO 81 | Billing And Compliance UpdateRICK GAWENDA, PT, is a licensed physical therapist with over 27 years of experience and currently serves as the founder and President of Gawenda Seminars & Consulting, Inc. He graduated with a Bachelor of Science degree in Physical Therapy from Wayne State University in Detroit, Michigan, in 1991. Mr. Gawenda is also Director of Finance for Kinetix Advanced Physical Therapy, a private practice with 2 locations.

He has provided valuable education and consulting to hospitals, private practices, skilled nursing facilities, and rehabilitation agencies in the areas of CPT coding, ICD-10 coding, billing, documentation compliance, revenue enhancement, practice management, and denial management as they relate to outpatient therapy services. Mr. Gawenda has presented nationally since 2004 and currently presents over 80 dates per year around the United States.

Mr. Gawenda is a member of the American Physical Therapy Association (APTA) and Michigan Physical Therapy Association (MPTA). Mr. Gawenda is a Past President of the Section on Health Policy & Administration of the APTA as well as a Past President of the Michigan Association of Medical Rehabilitation Program Administrators.

Mr. Gawenda is also the author of “The How-To Manual for Rehab Documentation: A Complete Guide to Increasing Reimbursement and Reducing Denials” and “Coding and Billing For Outpatient Rehab Made Easy: Proper Use of CPT Codes, ICD-9 Codes and Modifiers”.

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