Due to the CMS changes that were effective October 1, 2011, the RAI manual (Resident Assessment Instrument) has been revised to reflect the changes. The MDS changes included a revision on using co-treatment as a treatment approach. Below are the definitions of co-treatment differentiated by payer source. The changes are listed in the RAI manual in Chapter 3, page O-20.
For Part A:
When two clinicians, each from a different discipline*, treat one resident at the same time (with different treatments), both disciplines may code the treatment session in full. All policies regarding mode, modalities and student supervision must be followed. The decision to co-treat should be made on a case by case basis and the need for co-treatment should be well documented for each patient. (*We have clarified with CMS that co-treatment by two members of the same discipline is not allowed – asterisk added by Key Rehab)
For Part B:
Therapists, or therapy assistants, working together as a “team” to treat one or more patients cannot each bill separately for the same or different service provided at the same time to the same patient.
Therapists may utilize this technique when selecting treatment approaches for their Part A patients if it is clinically appropriate and when it is performed according to the definitions listed above. The treatment provided by each therapist must be directly related their own plan of care and it must be distinct from the other discipline’s treatment. Keep in mind that the documentation must support that the skills of each discipline were required for the entire time the activities are being performed. Some examples of clinically appropriate uses of co-treatment are as follows:
*Example from CMS: A SLP and an OT do a meal with a patient. The OT is working on feeding skills and fine motor coordination of the utensils and the SLP is working on swallowing skills. Both disciplines may code the full treatment session.
Other Suggestions from Key Rehab:
- Sit to stand transfers up to the sink to perform ADL’s. (PT and OT)
- Edge of bed activities for sitting balance and dressing tasks. (PT and OT)
- Gait training from bed to bathroom. (PT and OT)
- Static standing activity with UE reaching tasks. (PT and OT)
- Meal time activity with safe swallow techniques and self-feeding instruction. (ST and OT)
- Standing activity with word finding or problem solving activity (ST and PT)
Cognitively Impaired patients-
- Problem solving/sequencing tasks during an ADL. (ST and OT)
- Gait training around obstacles while sequencing or problem solving. (PT and OT/ST)
- Gait training to closet for clothing retrieval and dressing task. (PT and OT)
High functioning patients-
- Standing/balance activity on uneven surface while working on “brain games”. (PT and OT/ST)
- Dynamic sitting balance on Swiss ball while performing UE exercise. (PT and OT)
- Obstacle course navigation and problem solving task. (PT and OT/ST)