Co-Treatment vs. Duplication: Therapy Documentation Basics

If you work in a setting that offers multiple types of therapy, such as a skilled nursing facility (SNF) or inpatient/acute rehabilitation unit, you have probably, or eventually will encounter something called co-treatment.

So what exactly is co-treatment and how does it impact you as a therapist? According to Medicare, co-treatment is when different professional disciplines can effectively address a patient’s treatment goals, in a single therapy session. For example, a Physical therapist might be addressing balance training for improved functional mobility while an Occupational therapist focuses on ADL training for increased independence. Co-treatment is covered by Medicare, but as a therapist, you must follow specific rules to ensure documentation and billing is completed correctly so that rendered services are not seen as duplicate services by insurance companies.

Now that you know what co-treatment is, you might be asking yourself when exactly co-treating is appropriate? The answer provided by the ASHA, AOTA, and APTA is: when coordination between two disciplines will benefit the patient, not simply for scheduling convenience. Co-treating should also be limited to only two disciplines providing interventions during one single therapy session, so whether that is PT and OT or PT and ST, just no more than two disciplines at one time.

When documenting for a co-treatment session, be sure to include the following:

• The rationale for co-treatment
• The specific task and goal that was addressed by each therapist and how it is related and/or interdependent upon the goals of the other therapist
• Must be documented and explicitly state in the documentation, by both disciplines, that the interventions provided were part of a co-treatment session

***The most important part of documenting a co-treatment session is explaining why this is the correct treatment for this specific patient and how it will lead to better outcomes for the patient, specifically when compared to a 1:1, single discipline therapy session.

While accurate documentation is crucial, as a therapist you must also appropriately bill for the co-treatment session. How you bill will depend on which part of Medicare you are billing for as well as the collaborating disciplines and setting. Here are some general guidelines when billing different parts of Medicare:

• • Part A (SNF setting): If a patient receives therapy from two different disciplines in a single therapy session, then both therapists may separately bill for the entire treatment session.

• • Part B (outpatient hospital or clinic setting): If co-treatment occurs in this setting, therapists cannot bill separately, but can split the units billed between them, specifically for PT and OT. The units and total time billed must be equal to the total duration of the session performed.

**Please note: The exception to co-treatment billing for Medicare part B is if speech therapy is the second discipline. Since the codes billed by SLPs are typically not time based, if co-treating, SLPs should bill for one untimed session and the OT/PT should bill for all of the timed treatment codes.

***Also, if a PTA or OTA provides the co-treatment, you must bill using the respective modifiers, CO for OTA and CQ for PTA. Beginning in 2022, if more than 10% of services during one session are being provided by an OTA/PTA, Medicare will only provide reimbursement for 85% of the Medicare fee schedule for services.

Keep in mind, co-treating will be appropriate for some, but not all, patients and if providing this service, your documentation must clearly justify why co-treating is appropriate for that particular patient. If you provide a co-treatment session, but your documentation does not provide justification, then insurances can deem your services as “duplicate services” and decline reimbursement for those services.

Here are 4 tips to prevent duplication of therapy services:

• Educate all therapists: The claim will be denied if documentation shows two different disciplines treating the same goal or treatment area.

• Define the differences between each discipline, especially when addressing functional mobility, transfers, and/or balance.

• Relate the treatment session back to discipline-specific goals: Be sure to have at least one goal for each functional deficit and/or area that you plan to treat. For instance, if a PT plans to treat for gait deficits, there must be a SMART gait goal. Similarly, if an OT plans to treat for shower deficits, there must be a specific shower goal in their plan of care.

• Progress notes are important: When writing progress notes, be sure you are providing rationale for why your discipline-specific skilled therapy services are required for that particular patient.

If you find yourself in a situation where co-treating is the right choice for your patient, be sure to refer back to this guide to ensure you are appropriately documenting and billing for co-treatment services so that Medicare does not think you are duplicating services during your co-treats. For all of your therapy documentation and billing needs, be sure to check out HelloNote, an EMR documentation system made by therapists for therapists.

Resources:

Joint Guidelines for Therapy Co-Treatment Under Medicare

Co-Treatment Things to know and consider

How to Avoid Duplicating PT/OT Services

CMS Final Rule: Physical Therapy Medicare Guidelines 

Billing Examples Using CQ/CO Modifiers for Services Furnished In Whole or In Part by PTAs and OTAs