Physical Therapy Plan of Care Certification Requirements
Medicare physical therapy plan of care certication requirements are the same as an occupational therapy plan of care certification and speech language pathology plan of care certification.
According to CMS Chapter 15 Medicare Benefit Policy Manual:
“Certification requires a dated signature on the plan of care or some other document that indicates approval of the plan of care. It is not appropriate for a physician/NPP to certify a plan of care if the patient was not under the care of some physician/NPP at the time of the treatment or if the patient did not need the treatment. Since delayed certification is allowed, the date the certification is signed is important only to determine if it is timely or delayed. The certification must relate to treatment during the interval on the claim. Unless there is reason to believe the plan was not signed appropriately, or it is not timely, no further evidence that the patient was under the care of a physician/NPP and that the patient needed the care is required. “
Basically, your plan of care must be signed by the doctor who referred the patient or the non-physician practitioner who qualifies under Medicare guidelines as someone who may certify a plan of care.
Timely vs Delayed Plan of Care Certification
A timely certification must be attained “As soon as possible” according to Medicare guidelines. Medicare goes on to define “As soon as possible” to mean within 30-days of the initial evalution.
Medicare does not require that you stop treatment while waiting for the plan of care to be certified.
“Certifications are required for each interval of treatment based on the patient’s needs, not to exceed 90 calendar days from the initial therapy treatment. Certifications are timely when the initial certification (or certification of a significantly modified plan of care) is dated within 30 calendar days of the initial treatment under that plan. Recertification is timely when dated during the duration of the initial plan of care or within 90 calendar days of the initial treatment under that plan, whichever is less. Delayed certification and recertification requirements shall be deemed satisfied where, at any later date, a physician/NPP makes a certification accompanied by a reason for the delay. “
Acceptable reasons for a delayed plan of care will be determined by the reviewer, but I can tell you that simply indicating that you tried faxing the plan of care multiple times without proof of those attempts may not be justification enough.
Physical Therapy Plan of Care Elements
Medicare have published requirements for what must be contained in a plan of care. A physical therapy, occupational therapy, or speech language pathology plan of care must contain:
- Long Term Goals
- Type, Amount, Duration, and Frequency
Physical Therapy Evaluation and/or Plan of Care
Medicare Part B allows a physical therapy evaluation to include a physical therapy plan of care, but it also allows physical therapists to separate the initial evaluation and plan of care into two distinct documents.
If you are a therapist that finds it difficult to complete your initial evaluation AND your plan of care during the treatment session, then you may choose to have your plan of care in a separate document that can quickly and easily be generated and faxed to the certifying physician/NPP quickly.
Anthony Maritato, PT
Private Practice Owner / Physical Therapist
After starting a private practice physical therapy clinic in 2022 with his wife Kathy Maritato, PT, Tony and Kathy grew their practice to five locations across two states.
Now, Tony and Kathy enjoy spending time treating patients in the morning, coaching therapists in the evening, and being home to play with their dog Tucker and 4 boys.