Concurrent treatment is permitted by Medicare only for Part A patients in skilled nursing facilities (SNFs) and is subject to new restrictions effective October 1, 2010. Based on the therapist's judgment that more than one patient at a time can be treated while maintaining the complex skill level required for coverage by Medicare Part A, concurrent treatment is allowed for patients who have different goals or plans of care. As of October 1, concurrent treatment may involve no more than two patients. The session minutes (used to determine the patient's RUG level [Resource Utilization Group]) must be allocated between the patients. Medicare has a pre-determined formula that requires 50% of the minutes spent in concurrent treatment to be allocated toward a patient's actual treatment session. This is different from co-treatment, where two disciplines may simultaneously treat a patient—the clinicians determine the number of minutes allocated to the patient by each discipline.
Group treatment differs from concurrent treatment in that the patients are working on some common skill development or functional area. The longstanding Medicare group treatment rule in SNFs allows a maximum of four patients and up to 25% of therapy per week per discipline per patient. Group therapy participants must have the same or similar goals. The total minutes in a group session can be counted for each patient.
The implementation of concurrent treatment rules (2009 discussion of 2010 implementation) and the new student supervision guidelines create new challenges for the SNFs to assure consistent levels of patient care are maintained. Clinicians may feel the pressure and confusion experienced by SNF administrators and student supervisors must understand that Medicare does not allow for the student and the supervisor to treat patients separately.
Speech-language pathologists (SLPs) continue to be patient advocates and the new regulatory challenges do not change the primary focus of clinically appropriate care. The new rules may provide the SLP with increased opportunity for alternative treatment plans. SLPs may notice less pressure from SNF administrators as of October 1, because of the changing reimbursement rules surrounding concurrent therapy. Student supervision requirements must be carefully considered within patient care plans. The clinical parameters for individual and group treatment remain the same and total treatment minutes must still be recorded for each session. The new requirement to specifically report the mode of treatment (i.e., individual, concurrent, group) must now be noted and medical record documentation continues to require that each approach taken is clinically appropriate.
For further information, please contact Mark Kander at firstname.lastname@example.org or 301-296-5669, or Kate Romanow at email@example.com or 301-296-5671.