Options for counting 10-visit-day progress reporting periods
It used to be that counting to 10 was a pretty simple activity. However, if you are an outpatient therapy provider, this has become considerably more complicated over the last couple years – especially as it relates to managing progress review periods. This effort calls for a form of new math to help providers stay on top of events.
To be clear, there are times when the math works out pretty simply. A patient is treated for 10 visit days, and on the last visit day, G-codes are submitted with a signed progress report document. This is the best case scenario and one we all hope happens more times than not.
But reality is not always as clear as that example. What if the patient, on visit-day 8, has an appointment with her referring physician before the next therapy, and the therapist wants to provide a summary to the referring doctor. In this case, it’s likely that the therapist will create a progress summary to give to the physician. This satisfies the progress summary requirement but leaves the G-code timeline out in the cold.
Providers can utilize some strategies to cope with what happens when the counts get out of sync.
One option is to disregard the progress summary that was created for the physician and do another on the 10th visit day to coincide with the G-code process. This keeps the counts in sync but poses an extra burden for the therapist, who incurs extra time documenting the patient status.
Another option is to submit the G-code early with the progress summary. CMS’ language isn’t exactly clear on whether this is the appropriate or desired action. It clearly meets the idea of “at least every 10 visit days” but it isn’t exactly “every 10 business days.” Different providers will have different policies on whether this is an appropriate interpretation of the rule.
A third option would be to submit the G-codes on schedule at the 10th visit day and not submit another progress summary until the next 10 visit days are complete (12 visit days later). This means that, on average, the progress summaries are being submitted every 10 days, but the time frame is a little flexible for any given progress summary. Again, different providers will have different ideas on whether or not this is a good idea.
Regardless of how your organization manages the 10–visit-day math problem, the goal remains to provide the best care for patients while not wasting time and money. Each of these approaches represents a different view of how best to remain compliant, competitive and efficient. One answer may not fit everyone. Your best bet is to pick one, be consistent and get good at managing it.