Blog FACTS

  • A weekly blog for the aquatic therapy industry hosted by industry guru Andrea Salzman, MS, PT, Founder of the Aquatic Resources Network.

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Supervision

October 18, 2008

Great download: The APTA answers your frequently asked billing questions

Answers to these questions (PDF) and more:

[Editor's note: The APTA answer to the question about whether therapists must have exclusive use of a community pool for Medicare patients is no longer accurate. Since this audioseminar took place Medicare has changed its policy to allow therapists to use a PORTION of a pool for their clients.]

SAMPLE QUESTIONS ANSWERED IN THIS PDF:
Q: Is the 2008 therapy cap of $1810 the allowable rate or actual payment received?

Q: Why do the therapy caps not apply in outpatient hospital departments?

Q: Is it okay to offer Medicare patients an “aftercare” program if they use up the cap at a
reduced rate or flat fee? What if the PT or PTA is also certified as a Personal Trainer or
CSCS?

Q: If a Medicare beneficiary has therapy in an outpatient hospital department (exempt
from the cap) and later goes to a private practice, does the private practice have to include any money spent by Medicare at the hospital based facility?

Q: Does the Medicare program require a referral/prescription/order for outpatient
physical therapy services?

Q: Are physical therapists allowed to bill for the plan of care? Is the code the same as a
progress note?

Q: Does the 90 day recertification period apply to both Medicare A and Medicare B
residents in a SNF? Does the fact that we bill for the services provided to our outpatient
beneficiaries on the UB-04 form make a difference?

Q: Can you tell me if there are any Medicare regulations or policies on whether or not a
private practice can determine how many Medicare referrals they will take?

July 05, 2008

Ask ARN: Must therapy pools supply lifeguards during aquatic therapy sessions?

The Aquatic Resources Network gets questions from clinicians each day. We think everyone should learn from the answers!

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Question: What kind of policy should we have regarding posting a lifeguard on duty at the pool? Are therapeutic pools held to the “public pool” standard?

Answer: There are over 100 bathing codes in effect in the U.S. and no two of them have identical wording concerning lifeguards. In most states, therapy pools are considered "public" pools and are subject to all the same codes and regulations as any other public pool in the state.

Some states have a “semi-public" or "special pool" or “therapeutic pool supervised by a licensed medical practitioner" category. Since surveillance requirements vary from state to state depending on the categorization, each practitioner should make himself aware of the requirements which pertain to his state or locality.

Regardless of whether or not a state code requires that lifeguards be posted, the facility is still required to provide a safe environment, and to provide rescue assistance and necessary First Aid.

The prevailing standard that public pools must hold to includes the following requirements:

  • The standard of care in the industry (in the U.S.) is the "10/20 Supervision Rule". Trained and qualified lifeguards must be posted in a way that they can observe and scan their entire area of responsibility once every 10 seconds, and respond to and manage an emergency situation within another 20 seconds.
  • Lifeguards should be properly dressed in uniforms (provided and paid for by the employer) and readily identifiable to patrons.
  • At least two certified or licensed lifeguards should be in attendance at all public pools at all times the pool is in operation.
  • Lifeguards should have no duties to perform other than the close general supervision of participants in water contact activities.
  • Lifeguards should be alert, rotate to a new position at least once every 40 minutes, and be given frequent relief breaks from surveillance duties.
  • The number of lifeguards should be adequate for the activities being conducted, the size and shape of the facility, and environmental conditions which might limit the ability to provide supervision.
  • Lifeguards should be at least 18 years old, medically fit, have good eyesight, be physically capable of meeting the demands of the job, possess current certifications or licenses (in lifeguarding, CPR, and First Aid) from a recognized training agency, have adequate specific training for the facility, and be qualified and practiced in emergency procedures and other job aspects including use of rescue equipment (a minimum of four hours/month inservice training).

Source: Osinski A. Aquatic Therapy Listserv. Aquatic Consulting Services: San Diego, CA; 2001. For more information: Aquatic Consulting Services, Phone (619) 224-3100, Hotline (900) 446-6075 x 820. Web: www.AlisonOsinski.com

July 04, 2008

Infant swimming A toddler slips out of the house and heads for the family swimming pool. The boy falls in the water, and sinks, but something amazing happens next. Instead of drowning, he flips on his back, floats to the top and cries for help.

Too good to be true? You decide! Watch the video making the rounds on the Internet.

An organization called Infant Swimming Resource is teaching baby aquatic survival skills and drowning prevention classes to infants as young as 6 months old.

Harvey Barnett Ph.D. and his wife JoAnn have developed Infant Swimming Resource (ISR) into a nationally recognized program with a specific mission: prevent childhood drowning through specialized survival training. According to their statistics, since ISR’s inception in 1967 there have been more than 1700 aquatic survivals witnessed and 783 survivals unwitnessed.

Read more on becoming an instructor.

March 31, 2008

Non-PTs billing for PT services. Is it allowed? Part 1

At Aquaticnet.com, we often get the following question:

Can my exercise physiologist/ athletic trainer/ personal trainer/ massage therapist work with clients and bill for services under my physical therapist's license?

It's such a hot topic, we'll discuss it in 3 parts.

PART 1: 
The practice of physical therapy is different in each state in the union. The only way to understand what your state allows is to view your state's PT Practice Act.

Each state has different restrictions, but all states say the following: Physical therapy can only be performed by physical therapists, physical therapist assistants and physical therapy aides.

Each state differs on what it allows aides to do. Some states allow physical therapy aides to perform limited hands-on treatment under the direct supervision of a physical therapist or PTA. Other states do not allow aides to perform any treatment at all, limiting them to housekeeping and transport activities.

For example, Minnesota allows PTs to delegate some "tasks" to aides. Tasks are routine acts, performed under the line-of-site supervision of the PT. The aide is not allowed to make any alteration in the plan, or to progress the patient. The therapist must treat the patient at the beginning and end of treatment and the aide cannot provide the bulk of the treatment (otherwise, it would not be considered skilled care).

MN classifies anyone who is not a PT or a PTA as an aide. Even if that person is a highly trained clinical exercise physiologist, they become an AIDE when working under the supervision of a PT and when billing under the PT's provider code.

Therefore, if you are billing under the PT provider code, you must look to your state practice act to determine what your exercise physiologist is allowed to do. Whatever your state allows AIDES to do, your exercise physiologist can do -- no more.

If, in contrast, your exercise physiologist is operating under his/her own license, and is billing under his/her own provider code, then the exercise physiologist can do whatever your state permits its exercise physiologists to do.

In Minnesota, exercise physiologists are not recognized as licensed providers and do not have billing provider numbers. This does not mean your exercise physiologist cannot work with clients. It does mean that there your exercise physiologist cannot bill Medicare or most insurances for services; nor can he/she present these services as PT.

However, there are many personal trainers and exercise physiologists working 1:1 with clients in the water across the US. These fitness or exercise services are useful and typically legal, presuming the non-PT provider does not:

1. present himself as providing "physical therapy"
2. do not infringe on other profession's scope of practice as outlined by the state
3. do not fraudulently bill under PT

* One last note. Minnesota is the only state of which I am aware, where athletic trainers are permitted to work in outpatient PT clinics under the direct supervision of a PT and provide more than "aide" duties. The Minnesota ATC practice act is in conflict with the Minnesota PT practice act and allows ATCs to provide many "physical therapy" services when supervised by a PT.

This is a gray area for outpatient clinics and some choose not to allow athletic trainers to take advantage of this fact. I only mention it because, in Minnesota, you might be able to make an argument for using an athletic trainer and billing under PT. You cannot make the same argument for an exercise physiologist or massage therapist. Also, keep in mind that no matter what Minnesota allows, Medicare (and many other payers) will not allow anyone but a PT or PTA to bill for "physical therapy" services.

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