LCD for Occupational Therapy (L17637)

 

Contractor Information

Contractor Name 

BlueCross BlueShield of Tennessee (Riverbend Government Benefits Administrator) 

Contractor Number 

00390 

Contractor Type 

FI 

 

LCD Information

LCD ID Number 

L17637 

 

LCD Title 

Occupational Therapy 

 

Contractor's Determination Number 

L17637 

 

AMA CPT / ADA CDT Copyright Statement 

CPT codes, descriptions and other data only are copyright 2007 American Medical Association (or such other date of publication of CPT). All Rights Reserved. Applicable FARS/DFARS Clauses Apply. Current Dental Terminology, (CDT) (including procedure codes, nomenclature, descriptors and other data contained therein) is copyright by the American Dental Association. © 2002, 2004 American Dental Association. All rights reserved. Applicable FARS/DFARS apply.  

 

CMS National Coverage Policy 

  • Social Security Act, Title XVIII, section 1862(a)(1)(A) allows coverage and payment for only those services that are considered to be reasonable and medically necessary.
  • Social Security Act, Title XVIII, sections 1861(g)(s)(u), and (cc) establish definitions for services, institutions, and other Medicare terms.
  • Social Security Act, Title XVIII, section 1835 (a)(C) establishes conditions for payment of claims to institutional providers of outpatient occupational therapy services, including certification and plan of treatment requirements.
  • Social Security Act, Title XVIII, section 1834 (K)(5) incorporates the provisions in the Balanced Budget Act (BBA) of 1997; Section 4541 (a)(2) to require payment under a prospective payment system of outpatient rehabilitation services.
  • 42 Code of Federal Regulations (42CFR) Parts:
    • 409 includes the definition of ‘reasonable and necessary’ therapy services that applies to both Part A and Part B services.
    • 410 describes the benefits to be paid under Medicare Part B, including outpatient occupational therapy services.
    • 411 describes those specific services excluded from Medicare or that are subject to limitations on payment.
    • 414 describes the provisions of payment for Part B services under a fee schedule and for payments for prosthetics and orthotics.
    • 420 describes specific Medicare program integrity requirements to prevent fraud and abuse. It also sets forth appeal rights of providers.
    • 421 identifies the activities required of the fiscal intermediaries and carriers that process Medicare claims.
    • 424 describes the conditions for Medicare payment, including those governing Part B outpatient occupational therapy services. In particular, it sets forth certification, plan of treatment, and CORF requirements.
    • 484 includes the personnel qualifications that Medicare requires for identification as an occupational therapist or an occupational therapy assistant.
    • 485 sets forth conditions for providers in CORFs.

 

  • Medicare General Information, Eligibility, and Entitlement Manual (Pub 100-1), Chapter 4, Section 50.
  • Medicare Benefit Policy Manual Chapter 12 and 15, Sections 220, 230.
  • Medicare Claims Processing Manual (Pub 100-4), Chapter 5.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 150.1.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 240.3.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section160.2.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 30.1.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 270.4.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 150.5.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Sections 160.3 and 160.7.1.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 150.8.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 160.15.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 20.2.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Sections 150.4 and 160.12.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 30.5.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 160.16.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 270.1.1.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 10.2.
  • Medicare National Coverage Determinations Manual (Pub 100-3), Chapter 1, Section 160.13.
  • Outpatient Occupational Therapy/CORF Manual (Pub 9), Sections 250-253 outlines covered and non-covered CORF services; and provisions of CORF services.
  • Outpatient Occupational Therapy /CORF Manual (Pub 9), Sections 270, 271, and 273 outline conditions of coverage for outpatient occupational and physical therapies.
  • Program Memorandum A-03-011 - Changes in Payment for Certain Services Provided by Outpatient Occupational Therapy (OPT) Providers Under the Medicare Physician Fee Schedule (MPFS).
  • Program Memorandum AB-03-018: Implementation of the Financial Limitation for Outpatient Rehabilitation Services.
  • Program Memorandum AB-02-161: Coverage and Billing Requirement for Electrical Stimulation for the Treatment of Wounds.
  • Program Memorandum AB-02-156: Coverage and Billing for Neuromuscular Electrical Stimulation (NEMS).
  • Program Memorandum AB-02-078: Provider Education Article: Medicare Coverage of Rehabilitation Services for Beneficiaries With Vision Impairment.
  • Program Memorandum AB-01-68: Consolidation of Program Memorandums for Outpatient Rehabilitation Therapy Services.
  • Program Memorandum AB-00-14: Questions and Answers Regarding the Prospective Payment System (PPS) for Outpatient Rehabilitation Services and Occupational Medicine Current Procedural Terminology (CPT) Coding Guidance.

 

 

Primary Geographic Jurisdiction 

Tennessee
 

 

Secondary Geographic Jurisdiction 

Alaska
Alabama
Arkansas
Arizona
California
Colorado
Connecticut
Florida
Georgia
Hawaii
Iowa
Idaho
Illinois
Indiana
Kansas
Kentucky
Louisiana
Massachusetts
Maryland
Maine
Michigan
Minnesota
Missouri
Mississippi
North Carolina
North Dakota
Nebraska
New Jersey
New Mexico
Nevada
New York
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Utah
Virginia
Vermont
Washington
Wisconsin
West Virginia
Wyoming
 

 

Oversight Region 

Region IV
 

 

 

Original Determination Effective Date 

For services performed on or after 09/30/2005  

 

Original Determination Ending Date 

 

 

Revision Effective Date 

For services performed on or after 01/01/2008  

 

Revision Ending Date 

 

 

Indications and Limitations of Coverage and/or Medical Necessity 

General Guidelines




This policy discusses traditional Occupational Therapy assessments and active therapies as performed in the facility outpatient (hospital, CORF, etc.) and the Inpatient Rehabilitation Facility environment. These services are not limited to Occupational Therapists but may also be performed by Physical Therapists acting within their scope of practice. Assistants as defined within Medicare regulations may also perform these services unless otherwise specified in the regulations or in the text of this policy. Due to the significant overlap between disciplines, the following related policies should be referenced in order to obtain a complete picture of coverage limitations:

Physical Therapy: The Physical Therapy LCD discusses traditional Physical Therapy assessments and active therapies regardless of the discipline performing the service.
PM&R Modalities: The PM&R Modalities LCD discusses adjunctive modalities regardless of the discipline performing the service.
Wound Care: The Wound Care LCD discusses the routine care of chronic wounds regardless of the discipline or provider performing the service.
Low Vision Rehabilitation: The Low Vision Rehabilitation LCD covers Occupational Therapy interventions as they are used in programs to develop compensatory techniques for the visually impaired.
Speech Therapy: The Speech Therapy LCD addresses Speech Therapy, which occasionally overlaps with the services of other therapy disciplines.
Dysphagia Therapy: The Dysphagia Therapy LCD addresses therapeutic interventions for dysphagia regardless of the discipline performing the intervention.

 

Definition of Occupational Therapy Services



Occupational therapy services are a part of a constellation of rehabilitative services designed to improve or restore physical functioning following disease, injury, or loss of a body part or, where function has been permanently lost or reduced by illness or injury, to improve the individual's ability to perform those tasks required for independent functioning. Current occupational therapy practice typically emphasizes functionally based activities directed toward a goal of enhancing performance through the adaptation of activity demands, the process or the environment, or through instruction in compensatory techniques. Physical therapists use the clinical history, systems review, physical examination, and a variety of evaluative techniques to characterize individuals with impairments, functional limitations and disabilities. Impairments, functional limitations and disabilities thus identified are then addressed in the design and implementation of therapeutic interventions tailored to the specific needs of the individual patient. The Medicare Part B benefit pays for Physical therapy services performed by or under the supervision of Physical therapists that:

1) practice within the scope of their state practice laws;
2) comply with Medicare coverage policy; and
3) are determined to be ‘reasonable and necessary’ for the individual patient’s condition.



Reasonable and Necessary Skilled Services

Intervention with Occupational Therapy services is indicated when the diagnosis established by the physician supports utilization of the intervention; there is documentation of objective physical and functional limitations; the plan of care incorporates those treatment elements that are expected to result in improvement of these limitations in a reasonable and generally predictable period of time (reasonable); and comparable results would not be anticipated with this disease process in the absence of the intervention (necessary). Intervention is also occasionally warranted to establish a safe and effective maintenance program when such a program is necessary to prevent deterioration in connection with a specific disease.

In order to be considered for coverage, Occupational Therapy Services must be medically reasonable and necessary to the treatment of the patient's illness or injury. Medical necessity determinations will be based on the following factors:

DIAGNOSIS SPECIFIC NECESSITY: The services must be considered under accepted standards of medical practice to be a specific and effective treatment for the patient's condition, i.e. specific, effective, and necessary for the disability in the setting of the underlying disease process that caused the disability.

· The patient must have a physical impairment that creates a significant functional limitation or dependence upon assistance or supervision from another person for self-care or mobility services.

· Routine recovery periods for patients with certain illness are expected without the services of a therapist. If comparable results would be anticipated with a given disease process (e.g. routine post surgical debilitation) in the absence of the intervention, the intervention of a therapist is not medically necessary. In the unusual instance where skilled Occupational Therapy services are required, the medical record must clearly convey the necessity for skilled services of the therapist as opposed to the presumptive need for restorative nursing care and unskilled custodial assistance.



Examples of medically necessary skilled services:

· The evaluation and reevaluation (as required) of a patient’s level of function by administering diagnostic and prognostic tests;

· The selection and teaching of task-oriented therapeutic activities designed to restore physical function;

· The planning, implementation, and supervision of individualized therapeutic activity programs as part of an overall active treatment program for a patient with a diagnosed psychiatric illness;

· The planning and implementation of therapeutic tasks and activities to restore sensory-integrative function;

· The teaching of compensatory techniques to improve the level of independence in the activities of daily living;

· The design, fabrication, and fitting of orthotic and self-help devices.




REASONABLE PROBABILITY OF IMPROVEMENT: The goal of services must typically be to restore or improve functional ability. There must be a reasonable expectation that significant improvement in the patient's overall functional ability will occur in a reasonable and generally predictable period of time. Complete restoration of function is often not achievable but measurable and functionally significant improvement must be considered a likely outcome.

In some instances the restoration potential of a patient is not the deciding factor in determining whether skilled services are needed. Even if improvement is not possible, a patient may need services to prevent further deterioration or preserve current capabilities, or the services must be necessary for the establishment of a safe and effective maintenance program required in connection with a specific disease state. In most instances ongoing maintenance does not require Occupational Therapy services (see below). In the unusual instance that continued skilled Occupational Therapy services are required to prevent further deterioration, the medical record must clearly convey the necessity for skilled services of the therapist as opposed to the presumptive need for unskilled maintenance services.


DEMONSTRATED PROGRESS: For continued coverage, the patient must demonstrate significant and measurable functional progress over time. Failure to progress over a several week period (“a plateau”) typically indicates that there is no longer a reasonable expectation of improvement in a “reasonable and generally predictable” period of time. In the unusual instance that continued skilled Occupational Therapy services are required due to a unique expectation of continued significant improvement, the medical record must clearly convey the necessity for skilled services of a therapist as opposed to the presumptive need for either unskilled maintenance services or the termination of the episode of care.

APPROPRIATE TYPE, FREQUENCY AND DURATION: The type, frequency and duration of services must be medically necessary for the patient's disability and underlying medical condition under accepted medical and occupational therapy practice standards.

TYPE
The type of service must be generally considered to be safe, effective, necessary and appropriate for the disability and medical condition based on:

· General acceptance as standard of care by the medical and occupational therapy disciplines in the United States (typically well-established services)

· Peer-reviewed and evidence based literature that supports the use of the service (typically newer, potentially investigational, controversial or unproven services).



Services of Occupational Therapists and Physical Therapists frequently are required concurrently on the same patient. For a service to be medically necessary when multiple disciplines are involved, it must not be duplicative of a service provided by another discipline

FREQUENCY

· Daily sessions (five times per week) are anticipated during the moderately intensive program of a therapy based SNF stay

· Although daily sessions may be necessary during outpatient therapy, particularly during the first week or two of a program or during a short (2-4 week) intensive course of therapy, sessions occurring more than three times weekly are not typically medically necessary for most outpatient treatment regimens.

· In the outpatient or Skilled Nursing Facility environment it is usually not medically necessary to have more than one treatment session per day. More than 4 units of OT active therapy per day (including both individual and group services) is not typically medically necessary; more than four units (including no more than two untimed units) of individual active therapy or five units (including no more than two untimed units) of combined active and group therapy in a single day will be denied as exceeding the normal needs for therapy outside of an IRF. However appeals will not be bound by this determination in the event that rare and exceptional situations are medically necessary and supported by additional medical records. In atypical situations requiring daily interventions (outpatient therapy where the intensive daily requirement exceeds two to four weeks) or multiple daily sessions (SNF or outpatient), the medical record must clearly justify the unusual medical need for services of this intensity as opposed to a more typical level of intervention.

· Inpatient rehabilitation typically requires multiple or extended sessions per day, either targeting several impairments (OT) or spread across several disciplines (e.g. PT and OT).



DURATION

· Depending on the severity of the patient's condition, the usual active treatment session provided in the outpatient setting is from 45 to 60 minutes (excluding modalities) and is typically an hour or longer in the IRF and inpatient Part A SNF environment.

· Atypical situations requiring shortened sessions should have the unusual medical need clearly documented in the medical record.




RELATED TO TREATMENT PLAN:
By regulation, services must be directly related to a written plan of treatment. Services (other than assessment) not relating to the written treatment plan or performed prior to the development of the treatment plan are not covered by regulation but are additionally considered not medically necessary. They are considered not medically necessary since the determination of patient needs and strategy for best meeting those needs (the plan of care) has not yet been determined or does not address those services.

Services performed under a treatment plan that has not been reviewed by a physician within the timeframes specified by regulations (at least 90 days after therapy began) are not covered by regulation but are additionally considered not medically necessary. They are considered not medically necessary since the patient’s medical needs change over time and in response to therapy so the strategy for best meeting those changing medical needs (the revised plan of care) has not been determined. If the referring (patient’s treating) physician does not re-examine the patient as part of the certification or recertification process, the medical necessity of continued services will depend solely on clear and unambiguous documentation in the therapy records to justify those services. (Note: This LCD only discusses the demonstration of medical necessity. Administrative requirements regarding certifications, physician examinations, etc are covered in the Medicare regulations.)

SKILLED SERVICE:
Occupational therapy services are only covered when they are skilled services. To be considered a skilled occupational therapy service, the service must be so inherently complex that it can be safely and effectively performed only by, or under the supervision of, an occupational therapist, physician, or qualified personnel. Occupational therapy services that do not require the professional skills of a qualified occupational therapist to perform or supervise are not covered by regulation but are additionally considered not medically necessary since the clinical (medical) skill of the therapist is not medically indicated.

MAINTENANCE
Maintenance programs do not require the supervision of a therapist. However, it may require the specialized knowledge and judgment of a qualified therapist to design and establish a maintenance program based on an initial evaluation and periodic reassessment of the patient's needs, capacity, and tolerance, and to provide initial instruction for the patient or family members to carry out the program. For example, a patient with Parkinson's Disease who has not been under a rehabilitation regimen may require the services of a qualified therapist to determine what type of exercises will contribute the most to the maintenance of his present level of functioning.

A brief period of practice may be required for the patient and/or patient’s caregivers to learn the steps of the task, to verify the task’s effectiveness in improving function, and to check for safe and consistent performance. This is considered part of “establishing” the maintenance program.

The skilled services of a therapist may be required for:

· The design of a maintenance regimen to delay or minimize functional deterioration in patients suffering from a chronic disease;

· Instructing the patient or family members in carrying out the maintenance program; and,

· Infrequent reevaluations required to assess the patient's condition and adjust the program.



The skilled services of a therapist are not required for:

· Services related to activities for the general good and welfare of patients (i.e., general exercises to promote overall fitness and flexibility);

· Repetitive exercises to maintain gait or maintain strength, endurance and current level of functioning;

· Assisted walking such as that provided in support for feeble or unstable patients;

· Range of motion and passive exercises that are not related to restoration of a specific loss of function, but are useful in maintaining range of motion in weakened or paralyzed extremities;

· Training programs related to occupational skills or skills that are normally taught to unimpaired individuals and which would require no significant modification for the patient;

· Maintenance therapies after the patient has achieved therapeutic goals; and

· Therapies for patients who show no further meaningful progress.




NONSKILLED SERVICES
A condition that does not ordinarily require skilled services may require them because of special medical complications. Under those circumstances, a service that is usually non-skilled (such as those listed in 42CFR409.33(d)) may be considered skilled because it must be performed or supervised by skilled rehabilitation personnel. In the unusual instance where, because of medical complications, a nonskilled service requires the clinical skills of a therapist in order to be safely performed, the medical record must clearly convey the necessity for skilled services of a therapist as opposed to the presumptive need for the skills of a family member or aide. The medical complications and the skilled services they require must be clearly documented in nursing or therapy notes and should also be justified by physicians' orders.

NURSING SERVICES
Regulations in 42CFR409.33 identify services that could qualify as either skilled nursing or skilled rehabilitation services. In a facility setting nursing services are considered to be ancillary services that are integral to the administration of patient care. These nursing services are not separately billable. Riverbend will not consider services that are typically performed by nurses (in most facilities) to require the specific skills of an occupational therapist unless the medical record clearly conveys the necessity for the involvement of the therapist as opposed to the presumptive inclusion as an ancillary nursing service. In these cases the involvement of the occupational therapist will be considered not medically necessary even though the service itself may be medically necessary. The following sections identify joint services in which the therapist may need to be involved, but does not imply that specific involvement will translate to an identifiable separately billable service.

Patient care plan development
The development, management, and evaluation of a patient care plan based on the physician's orders constitute skilled therapy services when, because of the patient's physical or mental condition, elements of medical care require the involvement of a occupational therapist in order to meet the patient's needs, promote recovery, and ensure medical safety as it relates to conditions typically addressed by Occupational Therapists and outside the usual expertise of registered nurses. Involvement in a care plan for personal care services is only necessary when the aggregate of those services requires the involvement of the therapist. An example of a possible need for occupational therapy involvement is an aged patient with diabetes and significant angina who is recovering from an open reduction of a femoral neck fracture. This patient requires, among other services, a program to restore strength and resume ambulation.

Although a nurse or properly instructed non-clinical person could perform the individual restorative services (nutrition, activity, etc.) for this patient, only a nurse or therapist would have the ability to understand the inter-relationships between the services. Due to the high potential for serious complications, such an understanding is essential to ensure the patient's recovery and safety. Under these circumstances, the management of the plan of care would require the skills of a nurse or therapist even though the individual services are not typical skilled therapy services. The need for the development of the program to restore the ability to ambulate may involve other considerations in a complex patient. This would be an Occupational Therapy service if the Occupational Therapist managed the overall program in lieu of a physical therapist or if the complexities of the program exceeded the normal post-operative return to ambulation typically managed by the surgical nurse.

Skilled planning and management activities are not always specifically identified in the patient's clinical record. Therefore, if the patient's overall condition supports a finding that recovery and safety can be ensured only if the total care is planned, managed, and evaluated by the occupational therapist, it is appropriate to infer that skilled services are being provided. Services performed by occupational therapists that are specifically related to the development, management, and evaluation of a patient care plan as outlined above may be considered reasonable and necessary. This does not necessarily presume that the subsequent performance of the interventions included in the plan is necessarily reasonable and necessary or that the they are individually considered to be skilled. It also does not imply a separately billable service as that determination is defined by billing and coding guidelines.

Observation and assessment
Observation and assessment constitute skilled services when the skills of a occupational therapist are required to identify and evaluate the patient's need for modification of treatment or for additional interventions until his or her condition is stabilized. A patient with congestive heart failure may require observation to detect signs of decreasing cardiac compensation, a surgical patient may require close observation for falls in the immediate postoperative period, and patients with acute psychological symptoms may require skilled observation to ensure their safety. However, this observation would typically be considered a nursing service. Alternatively, the observation or assessment of the patient specifically to determine the safety and benefit of the occupational therapy treatment plan at any point in time would be a medically necessary Occupational Therapy observation service. This does not imply a separately billable service as that determination is defined by billing and coding guidelines.

Patient education
Patient education and training services constitute a significant portion of occupational services. These are skilled services if the occupational therapist or occupational therapist assistant under the supervision of the occupational therapist is necessary to teach a patient self-maintenance or if the particular expertise of the therapist is required because the subject matter would not normally be expected to be within the scope of the routine patient education provided by the facility nursing service.

For example, gait training after amputation would typically require the specialized skills of the therapist whereas assistance with ambulation after general surgery would be within the usual scope post-operative nursing care. Similarly, a patient with diabetic peripheral sensory neuropathy requires instruction to learn foot-care precautions, but those instructions can typically be provided by nursing as well as by occupational therapy. The establishment of compensatory techniques, on the other hand, would be beyond the typical limits of ancillary nursing care even though many specialized nurses are quite adept at this instruction in many post operative situations.

SPECIFIC OCCUPATIONAL THERAPY SERVICES

Ongoing assessment of rehabilitation needs and potential: Such services are concurrent with the management of a patient care plan, including tests and measurements of range of motion, strength, balance, coordination, endurance, functional ability, activities of daily living, perceptual deficits. These services are skilled services although they may not always constitute separately billable services. That determination is defined by billing and coding guidelines.

Therapeutic exercises: Therapeutic exercises which, because of the type of exercises employed or the condition of the patient, must be performed by or under the supervision of a qualified occupational therapist to ensure the safety of the patient and the effectiveness of the treatment may be considered to be Occupational Therapy skilled services. Therapeutic exercises are frequently used when Occupational Therapists provide typical physical therapy services (non task oriented exercises) but may also be used (task oriented exercises) to help achieve a purely Occupational Therapy goal. In this case the services are skilled when they are not merely repetitive.

Therapeutic Activities: Therapeutic activities which, because of the type of dynamic activities employed or the condition of the patient, must be performed by or under the supervision of a qualified occupational therapist to ensure the safety of the patient and the effectiveness of the treatment are traditional Occupational Therapy skilled services. Therapeutic activities are frequently used when Occupational Therapists provide typical physical therapy services (non task oriented exercises) and may sometimes be required in the early part of a therapy program in order to prepare the patient for the demands of the occupational therapy session.

Gait evaluation and training: Gait evaluation and training furnished to restore function in a patient whose ability to walk has been impaired by neurological, muscular, or skeletal abnormality is a skilled service; assistance due to general debilitation is not.

Range of motion exercises, Modalities and Personal care services: Range of motion exercises and Modalities are frequently used by Occupational Therapists in support of typical physical therapy goals, and are occasionally used as part of a traditional occupational program. Personal care services rarely meet the standards as a skilled service within an Occupational Therapy context. The training of compensatory techniques for personal care services is a skilled Occupational Therapy service, but the performance of or assistance with the service itself is not. These services are all discussed in the Physical Therapy LCD.

General and local conditioning: The general supervision of exercises (ether general or task oriented) which have been taught to the patient; including the actual carrying out of maintenance programs, (i.e. the performance of the repetitive exercises required to maintain function) does not typically require the skills of a therapist and thus does not constitute skilled therapy services. Similarly, repetitious exercises to improve gait, maintain or increase strength or endurance; passive exercises to maintain range of motion in paralyzed extremities; exercises which are not related to a specific loss of function or are performed independently by patients; and assistive walking to increase distance as well as other routine assistive exercises do not constitute skilled therapy services. The skills of a occupational therapist are not medically necessary for the provision or supervision of such exercises.
Conditioning (routine exercise) services do not require the skills of qualified professional personnel and are not skilled services. In the unusual instance that skilled Occupational Therapy supervision is required, the medical record must clearly convey the necessity for the skilled services of the therapist as opposed to the presumptive need for unskilled assistance.

Skilled Services

 

Non-Skilled Services

 

Goal is to increase ROM, strength and function

Goal is to maintain ROM,

 

Gait training, if patient's ability to walk has been impaired (neuro-motor or structural damage) and when training can be expected to significantly improve the patient's ability to walk.

Gait training becomes non-skilled after the gait has been taught, when the goal is merely to improve strength, distance or endurance, and when the service consists primarily of assistance rather than actual neuro-motor retraining.

Resistive exercises, progressive resistive exercises, neuro-development technique, are considered skilled services.

Active and active assistive exercises can be given safely by a restorative or non-skilled person, although the program may require initial development by a therapist.

Evaluate the patient's needs for transfer training and design the special transfer training technique. Provide transfer training to patient, restorative staff and/or family

The restorative staff and/or family can safely and effectively perform repetitious carrying out the transfer method after transfer.

 

SPECIFIC SERVICES



Evaluation and re-evaluation guidelines

Occupational Therapy Evaluation (CPT 90003)
Evaluations are indicated prior to beginning therapy for determining the medical necessity of initiating rehabilitative or maintenance services. Patients must have evidence of a significant impairment that might respond to occupational therapy in order to warrant an initial evaluation.

Initial evaluations may be covered even when it is determined as a result of that evaluation that a skilled level of service is not required. Medical necessity exists as long as the patient’s condition suggested a need for the evaluation, even if the patient is not eligible for further treatment because it is determined that further therapy would not result in any significant improvement or that therapy would be otherwise unnecessary or inappropriate.

The evaluation covers a complete assessment of the entire patient, not just a single problem or system, although the focus of the assessment is the active condition or conditions necessitating occupational therapy. It reflects the chronicity or severity of the current problem, the possibility of multi-site or multi-system involvement, the presence of preexisting systemic conditions or diseases, and the stability of the condition. Factors that influence the complexity of the evaluation process include the clinical findings, extent of loss of function, social considerations, and the patient’s overall function and health status. Therapists also consider the level of the current impairments and the probability of prolonged impairment, functional limitation, and disability; the living environment; and the social supports (i.e., the potential for effecting an improvement in the patient’s functional ability).

Since the initial evaluation is a comprehensive assessment, typical clinical tests and measurements are indicated as integral parts of the comprehensive evaluation. Separate and distinct tests and measurements are not typically medically necessary since they are by definition unrelated. Please refer to the descriptions of codes that describe other tests and measurements discussed in the Physical Therapy LCD and in companion Coding and Billing articles.

If the patient presents with multi-system involvement and/or multiple site involvement, all areas/conditions should be assessed at the initial evaluation (i.e., cervical pain and knee pain; low back pain and rotator cuff; cervical pain and low back pain). Multiple initial evaluations are not medically necessary; only one evaluation should be used to assess all concurrent occupational therapy problems. Wheelchair evaluations, when medically necessary, are a part of a complete therapy evaluation (i.e. fulfilling all components as described in this section).

The initial evaluation is only medically necessary:

a) when any provider initiates a course of treatment commencing at least 6 months after the cessation of a prior course of treatment or

b) when a new provider (i.e. new facility, not a new employee) takes over a course of treatment following the transfer of patient care or

c) when an established provider initiates a new course of therapy for a new pathological process.



Partial or incomplete evaluations (except when the patient experiences a medical event that prevents the completion of the evaluation), and evaluations not meeting the documentation requirements defined below, will not be considered to be medically necessary. Evaluations require the skills of the occupational therapist; evaluations performed by occupational therapy assistants will not be considered to be medically necessary as the level of training and expertise is not sufficient to maximize the benefit to the patient and the authority to design the plan of care does not exist.

Initial evaluations from other therapy disciplines (e.g. Physical Therapy) performed on the same beneficiary may also be covered, provided the referral, evaluation, anticipated required services and plan of treatment are not duplicative. Multiple assessments to address the same problem at the same time are not medically necessary unless the medical record clearly supports a need for two distinct perspectives (e.g. OT and PT) on that problem.

Routine screening assessments and routine reassessments are not covered as Medicare does not cover routine screening and because routine occupational therapy screening is not medically necessary. An evaluation by a therapist is also non-covered when the evaluation is for a non-covered service (e.g. wheelchair ramp). Driving Assessments are non covered. In addition to the coverage considerations, all of these instances would be not medically necessary.

Although covered functional diagnoses are required, initial evaluations will not typically be subject to functional or pathological diagnosis edits; however they may be subject to other forms of review.

Occupational Therapy Re-Evaluation (CPT 97004)
The re-evaluation is a formal global assessment of patient status meeting all the requirements of the initial evaluation. Conversely, continuous evaluation of the patient’s progress is a component of ongoing physical therapy services. The reassessment of ongoing therapy is considered to be a continuous and routine aspect of any recurring intervention and is not billed separately from the charge associated with the intervention. In the absence of situations identified below, separate formal global re-evaluation during an episode of care is not considered to be medically necessary. Re-evaluations are not routinely covered solely for purposes of updating the plan of care although the indication for a re-evaluation, a significant change in the patient’s condition, frequently requires an update to the plan of care following the re-evaluation.

Therapy re-evaluations are covered and may be billed as a separate charge only if the documentation shows significant change in the patient’s condition that supports the need to perform a formal re-evaluation of the patient’s status. When a patient exhibits a demonstrable change in physical functional ability, a re-evaluation is covered to reestablish appropriate treatment goals and interventions. If a demonstrative change in a patient's functional ability or status occurs during an episode of ongoing therapy that warrants a wheelchair evaluation, it is covered as a part of a complete therapy re-evaluation.

A re-evaluation is medically necessary:

a) when there is a significant deterioration in function related to an ongoing pathological process and an ongoing or recently completed (6 months) course of therapy, or
b) when it is necessary to formally re-assess the patient a part of the decision to stop therapy.



Re-evaluations require the skills of the occupational therapist; re-evaluations performed by occupational therapy assistants will not be considered to be medically necessary as the level of training and expertise is not sufficient to maximize the benefit to the patient and the authority to modify the plan of care does not exist.

General Guidelines for Therapeutic Procedures

1. Therapeutic procedures are procedures that attempt to reduce impairments and improve function through the application of clinical skills and/or services The ultimate goals should be to increase functional abilities in self-care, mobility, or patient safety.

2. Use of these procedures requires that the practitioner have direct (one to one) patient contact.

3. Many procedures utilized by Occupational Therapists are also used by Physical Therapists. In the interest of avoiding confusion, procedures that are used more extensively by Physical Therapists are included in the Physical Therapy LCD; those that are used more extensively by Occupational Therapists are included here. Both policies are service specific, not discipline specific. Please refer to the companion policies identified at the beginning of this section for coverage conditions related to services not included below.

4. Services provided concurrently by physicians, physical therapists and occupational therapists may be covered if (and only if) separate and distinct goals are documented in the treatment plans, the specific services are non-overlapping, and each discipline is providing some service that is unique to the expertise of that discipline and would not be reasonably expected to be provided by the other disciplines.

5. Therapeutic procedures are typically effective in some clinical situations but not in others. Therapies will be considered medically necessary when used for diagnoses referenced in the "ICD-9 covered diagnoses" section in this policy. Therapeutic procedures used for other diagnoses will be considered to be not medically necessary. Medical records used to support an initial determination or an appeal should clearly demonstrate the requirements for coverage discussed above in order to refute a presumption of inappropriate use in those circumstances. However, unless specifically precluded elsewhere in this policy, non-covered diagnoses may be overturned if the impairment requires therapy and the medical record contains evidence that the non-covered diagnosis should be amenable to therapy in the instance of the individual patient.



97532: Development of cognitive skills to improve attention, memory, problem solving, (includes compensatory training), direct (one-on-one) patient contact by the provider, each 15 minutes:
This code describes interventions used by occupational therapists to enhance mental functions (e.g., attention, memory, perceptual, higher-level executive, sequencing, and time functions) with conditions such as psychiatric disorders, brain injury, and strokes to perform their occupational roles safely and independently in their environments.

· Cognitive skills are an important component of many occupational therapy tasks, but the techniques used to improve cognitive functioning are integral to the broader impairment being addressed. Cognition therapy techniques are therefore covered as component of the traditional OT approaches, but those services are better reported using other codes. Cognition treatment as a single therapy, and particularly cognition therapy used to address the goal of “improving cognition” has not been shown to be effective in the treatment of disease or in significantly improving outcomes. Cognition therapy alone, as coded by this CPT code, is not covered (investigational).

· Therapies directed to improving cognition are covered and medically necessary as a component of other coded services, and are thus reimbursable when billed as a component of those codes.

· Treatment that is focused on restoration of functions (i.e. to know where to locate clothes in order to get dressed) is covered as a component of the intervention designed to improve the function. Services provided to improve memory, billed as cognition therapy, are not covered. An evaluation to set up a maintenance or self help program is covered.



97533: Sensory integrative techniques to enhance sensory processing and promote adaptive responses to environmental demands, direct (one-on-one) patient contact by the provider, each 15 minutes:
Sensory integration (SI) interventions enhance sensory processing by persons with deficits in sensory systems (e.g., vestibular, proprioceptive, tactile) by increasing their ability to make adaptive sensory, motor, and behavioral responses to environmental demand. SI treatments are almost exclusively provided to a pediatric population for conditions such as autism, developmental disorders, ADD, CP, and motor apraxia and are rarely considered to be medically necessary in adults. Similar techniques used in treatment for adults, which may be considered medically necessary, are addressed under 97112.

These procedures are considered investigational for the treatment of adult patients. Similar to the case with cognitive skills (above), sensory integration is essential to task completion. It is therefore appropriate to use sensory integrative techniques as a part of normal occupational therapy procedures, but sensory integration as a discrete service is not medically necessary in adults.



97535: Self-care/home management training (e.g., activities of daily living (ADL) and compensatory training, meal preparation, safety procedures, and instructions in use of adaptive equipment) direct one on one contact by provider, each 15 minutes:
This procedure includes interventions to enable the performance of activities of daily living (e.g., dressing, bathing) and instrumental activities of daily living (e.g., meal preparation). This includes instruction in compensatory and adaptive techniques, instruction in the use of adaptive equipment/assistive technology, and instruction in safety procedures and emergency responses.

· This procedure is reasonable and necessary only when it requires the skills of a therapist, is designed to address specific needs of the patient, and is part of an active treatment plan directed at a specific outcome.

· The patient must have a condition for which training in activities of daily living is reasonable and necessary, and such training must be reasonably expected to restore or improve the functioning of the patient. Documentation must relate the training to expected functional goals that are attainable by the patient.

· This code should be used for activities of daily living (ADL) and compensatory training for ADL, safety procedures, and instructions in the use of adaptive equipment. It is not medically necessary for home instruction of an exercise program or for assistive services.

· Only the actual time of the provider’s direct contact with the patient is billable as reasonable and necessary. Documentation must support the number of services/units billed each visit.

· Standard medical treatment may generally require up to 12 visits over 4 weeks. Greater than 12 visits will typically constitute a flag to medical review to request records and review for medical necessity. Prolonged ( > 12 visits) courses of therapy will only be considered medically necessary when the medical record specifically identifies an unusual condition and specifically and unambiguously specifies the need for the total number of services provided, including the efficient use of the earlier visits in the series.

· The patient and/or caregiver must have the capacity and willingness to learn from instructions. The occupational therapist is expected to explain the benefits of the instruction in order to determine that the patient is motivated and desires to improve their level of function. Providing treatment to a patient that has been able to verbalize that they do not want to improve their functional level is not reasonable and necessary.



97537: Community/work reintegration (e.g., shopping, transportation, money management, avocational activities and/or work environment modification analysis, work task analysis, direct one on one contact by provider, each 15 minutes:
This procedure includes interventions to enable safe and efficient participation within the community and work environment. This includes, but is not limited to, community mobility, financial management, environmental analysis, and modification.

· This training may be medically necessary when performed in conjunction with a patient’s individual treatment plan aimed at improving or restoring specific functions which were impaired by an identified illness or injury and when expected outcomes that are attainable by the patient are specified in the plan.

· This training is medically necessary only when it requires the professional skills of a provider. Generally speaking, the professional skills of a provider are not required to effect improvement or restoration of function where a patient suffers a temporary loss or reduction of function or which could reasonably be expected to improve as the patient gradually resumes normal activities. Training that does not use techniques specifically targeted to the impairment (i.e. when the same instruction is equally applicable to a non-impaired individual) constitutes general education rather than skilled therapy. General activity programs and all activities, which are primarily social or diversional in nature, will be denied because the professional skills of a provider are not required.

· No more than 4-6 visits (with treatment time being 30-45 minutes in length) are typically medically necessary. Coverage beyond this time will typically signal a need for medical review. The clinical record must specifically and unambiguously document the unusual need for extended or prolonged services beyond 45 minutes per day and 6 visits. More than one hour in a given day or more than 9 visits total will be denied as not medically necessary, although (to accommodate the patient with clearly unusual and atypical needs) that limitation will not be binding upon appeals.

· Services which are related solely to specific employment opportunities, work skills or work settings are not reasonable and necessary for the diagnosis and treatment of an illness or injury and are excluded from coverage.



97542: Wheelchair management/propulsion training, each 15 minutes:
This intervention involves training the patient in wheelchair propulsion and safety techniques to facilitate mobility and transfers in the home or patient’s environment. This is a training code and should involve demonstration and instruction to the patient and/or caregiver in the use of the wheelchair in his/her environment.

· This procedure is considered reasonable and necessary only when it requires the professional skills of a therapist, is designed to address specific needs of the patient, and must be part of an active treatment plan directed at a specific goal.

· Visits made for restraint reduction are generally non-covered.

· A total of 2-3 visits should be sufficient with visit/treatment time being no greater than 30 minutes. Coverage beyond this level will be denied as not medically necessary although (to accommodate the patient with clearly unusual and atypical needs) that limitation will not be binding upon appeals.

· Wheelchair evaluations are covered under the DME benefit and are not separately covered for occupational therapists.



97545: Work hardening/conditioning; initial 2 hours:
97546: Work hardening/each additional hour

This intervention involves job simulation, highly structured focused tasks and activities designed for strengthening and endurance in order to increase work tolerance, pain tolerance, work habits and work behaviors.
Services for CPT 97545 and 97546 are related solely to employment restoring the ability to perform work-related functions; they are therefore not reasonable and necessary for the diagnosis or treatment of an illness or injury.

CPT 97755 - Assistive Technology Assessment

· Provider performs an assessment for the suitability and benefits of acquiring any assistive technology device or equipment that will help restore, augment, or compensate for existing functional ability in the patient (i.e. provision of large amounts of rehabilitative engineering).

· Utilization of this service should be infrequent. An assessment is comprehensive relative to the time period for which it is performed (i.e. it would not be medically necessary to perform multiple assessments for the same referral).

· This assessment is only medically necessary when performed at the specific request of a physician who is requesting:

o An evaluation for a specific device or class of device, OR
o A consultation regarding the availability and applicability of assistive devices relative to a specific impairment that cannot be effectively compensated by therapeutic measures.


· Reassessment for the same condition in the absence of a significant change in the patient’s condition is not medically necessary.



 

 

Coverage Topic 

Occupational Therapy
 

 

Coding Information

Bill Type Codes: 

Contractors may specify Bill Types to help providers identify those Bill Types typically used to report this service. Absence of a Bill Type does not guarantee that the policy does not apply to that Bill Type. Complete absence of all Bill Types indicates that coverage is not influenced by Bill Type and the policy should be assumed to apply equally to all claims.

 

 

 

Revenue Codes: 

Contractors may specify Revenue Codes to help providers identify those Revenue Codes typically used to report this service. In most instances Revenue Codes are purely advisory; unless specified in the policy services reported under other Revenue Codes are equally subject to this coverage determination. Complete absence of all Revenue Codes indicates that coverage is not influenced by Revenue Code and the policy should be assumed to apply equally to all Revenue Codes.

 

043X

Occupational therapy-general classification

 

 

CPT/HCPCS Codes 

Splinting, Strapping, and Casting

29065

APPLICATION, CAST; SHOULDER TO HAND (LONG ARM)

29075

APPLICATION, CAST; ELBOW TO FINGER (SHORT ARM)

29085

APPLICATION, CAST; HAND AND LOWER FOREARM (GAUNTLET)

29105

APPLICATION OF LONG ARM SPLINT (SHOULDER TO HAND)

29125

APPLICATION OF SHORT ARM SPLINT (FOREARM TO HAND); STATIC

29126

APPLICATION OF SHORT ARM SPLINT (FOREARM TO HAND); DYNAMIC

29130

APPLICATION OF FINGER SPLINT; STATIC

29131

APPLICATION OF FINGER SPLINT; DYNAMIC

29220