Harmony Healthcare Blog

Therapy Minutes Defined: Medicare Part A

Posted by The Harmony Team on Thu, Aug 03, 2017

Edited by Kris Mastrangelo


Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency

therapynursinghome.jpgThe Harmony HealthCARE Specialist Team provides the following information on how CMS (Center for Medicare and Medicaid Services) defines billable therapy minutes under the Medicare Part A SNF Benefit. 

While analyzing the operations of a SNF Rehabilitation Department, it is often revealed that education and re-education on the Medicare requirement for billable and non-billable minutes is a necessary component for systems refinement. 

To begin, only therapy minutes rendered since admission or readmission to the facility may be counted as billable minutes. The therapist’s time spent on documentation or on an initial evaluation are not include as billable minutes.  The therapist time spent on subsequent re-evaluations, conducted as part of the treatment process, should be counted as treatment time. 

When the resident returns to the SNF from a hospital stay, an initial evaluation must be performed upon readmission to the facility to initiate a therapy treatment plan. 

The Billable Treatment Time starts when the patient/resident begins the first treatment activity or task and ends when he or she finished with the last apparatus or intervention/task and the treatment is ended. 

Non-Billable Minutes 

  • Evaluation 
  • Documentation 
  • Time spent investigating a refusal or trying to persuade the resident to participate in treatment is not a skilled service and not be included in the therapy billable minutes. It is important for care planning purposes to identify why the resident is refusing therapy. 
  • Services provided at the request of the resident or family that are not medically necessary. 
  • Licensed professionals providing non skilled tasks. 

Billable Minutes 

  • Re-Evaluations or Augmentative Evaluations (Coming soon, downloads of samples) 
  • Set-Up time: The time required to adjust equipment or otherwise prepare for the individualize therapy of a resident, is the set-up time and may be included in the count of minutes of therapy delivered to the resident. 
  • Therapeutic Rest 

    A "therapeutic rest" describes a skilled level of service, i.e., skilled observation and is a covered service as part of the patient's treatment session. This skilled observation is necessary for patients with a compromised cardiopulmonary system, such as COPD, CHF, Pneumonia. 

    Under Medicare Part A regulations defined in the Federal Register, Final Rule for Prospective Payment System for Skilled Nursing Facilities, the time counted as billable treatment time (minutes): 

    "is a record of the time the beneficiary spent receiving therapy services, not a record of the therapist's time. Therapy time starts when the patient begins the first activity or task and ends when the patient finishes with the last apparatus and the treatment ends. Set-up time is included, as is time under the therapist's or therapy assistant's direct supervision.”

    In these circumstances, under The Medicare Part A Benefit, short rest periods between activities is included in the total billable time, whether or not there is skilled observation or monitoring of response. 
  • Caregiver Education: When the resident is present, caregiver education is counted as billable minutes but this must be documented in the resident’s record. Included the related portion of a meeting that meets this definition. 
  • When therapy is provided, staff need to document the different modes of therapy and set-up minutes that are being included on the MDS.  It is important to keep records of time included for each. 
  • At times a resident receives certain modalities that are partly skilled and partly unskilled; only the time that is skilled may be recorded on the MDS. 
    Example Skilled Modalities 
    • A resident is receiving TENS (transcutaneous electrical nerve stimulation) for pain management.  The portion of the treatment that is skilled, such as proper electrode placement, establishing proper pulse frequency and duration, and determining appropriate stimulation mode, is considered billable minutes and recorded on the MDS.

      Some modalities only meet the requirements of skilled therapy in certain situations. For example:  The application of a hot pack is often not skilled.
  • However, when the resident’s condition is complicated and the skills, knowledge and judgment of the therapist are required for treatment, then those minutes associated with skilled therapy time may be recorded on the MDS as billable minutes.

Ongoing attention and oversight to the simplest details set the pace for future Therapy Operational success.  Stay tuned as Harmony Healthcare International (HHI) provides you with tools and tips for your Rehabilitation Program Development.

Harmony Healthcare International (HHI) is available to provide assistance You can contact us by clicking here.  Looking to train your staff?  Join us in person at one of our our upcoming Competency/Certification Courses.  Click here to see the dates and locations. 

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Tags: Billable Therapy Minutes

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