CERT Audit: Most Common Therapy Errors in Noridian's Territory

Here's a summary of the common denials for errors found during Noridian's audits of all providers of physical therapy in the past three years. The data below is taken from the reports found here.

2009, May
97110 Therapeutic Procedure, one or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility
Missing copy of signed/dated treating physician's certification/recertification of the Physical Therapy (PT) plan of treatment for the billed DOS and daily PT log including times and units of service. Also need daily treatment note.

97140 Manual Therapy Techniques, one or more regions, each 15 minutes
Missing (1) the physician order for physical therapy, (2) the physical therapy evaluation, (3) the plan of care and (4) the treatment notes.

2008, November
97110 Therapeutic Procedure, one or more areas, each 15 minutes
Missing copy of signed/dated treating physician's certification/recertification of the Physical Therapy (PT) plan of treatment for the billed DOS and daily PT log including times and units of service. Also need daily treatment note.

97140 Manual Therapy Techniques, one or more regions, each 15 minutes
Missing (1) the physician order for physical therapy, (2) the physical therapy evaluation, (3) the plan of care and (4) the treatment notes.

97530 Therapeutic Activities, Direct, Patient Contact by Provider, Each 15 minutes.
Missing Physician (MD) order for Physical Therapy (PT), MD certification/recertification for PT, PT Plan of Treatment/Evaluation and PT notes to include minutes, Flow Sheet

2008, May
97110 Therapeutic Procedure, one or more areas, each 15 minutes
Missing copy of signed/dated treating physician's certification/recertification of the Physical Therapy (PT) plan of treatment for the billed DOS and daily PT log including times and units of service. Also need daily treatment note.

97530 Therapeutic Activities, Direct, Patient Contact by Provider, Each 15 minutes
Missing Physician (MD) order for Physical Therapy (PT), MD certification/recertification for PT, PT Plan of Treatment/Evaluation and PT notes to include minutes, Flow Sheet

97140 Manual Therapy Techniques, one or more regions, each 15 minutes
Missing (1) the physician order for physical therapy, (2) the physical therapy evaluation, (3) the plan of care and (4) the treatment notes.

97116 Therapeutic proocedure; gait training (includes stair climbing)
Missing daily treatment flowsheet that lists specific therapeutic activities/exercise performed and actual time involved performing each activity. Also requires certifcation and re-certification.

These findings from past audits are likely to guide the focus of future audits, not only with CERT but also with Medicare-RAC and Medicaid-RACs.