Do you recommend including concurrent therapy in your POC & rationale?  For group tx, there is a separate CPT code.  Many therapists may provide concurrent tx later in the plan of care when patient is safer.



Modes of Therapy are outlined in Chapter 3 of the Resident Assessment Instrument (RAI) Manual, under Therapies, Section O. The RAI Manual instructs that “When developing the plan of care, the therapist and assistant must determine which mode(s) of therapy and the amount of time the resident receives for each mode and code the MDS appropriately. The therapist and assistant should document the reason a specific mode of therapy was chosen as well as anticipated goals for that mode of therapy.”

Further, the FY2020 Final Rule emphasized, “Group therapy is not appropriate for either all patients or all conditions, and in order to verify that group therapy is medically necessary and appropriate to the needs of each beneficiary, SNFs should include in the patient’s plan of care an explicit justification for the use of group, rather than individual or concurrent, therapy. This description should include, but need not be limited to, the specific benefits to that particular patient of including the documented type and amount of group therapy; that is, how the prescribed type and amount of group therapy will meet the patient’s needs and assist the patient in reaching the documented goals.”

Therapy staff should be educated on CMS’ expectations to clearly justify the patient’s individual clinical needs and ability to benefit from non-individual treatment modes. Rehab software does not always cue therapists to document according to this CMS directive, but in most cases, this is an option from the software. As a best practice, clinicians should also include designated mode of treatment(s) within the therapy clarification order.


Blog by Stacy Baker, OTR/L, RAC-CT, CHC, Proactive Medical Review

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