Recovery Auditor findings show incorrect billing of untimed therapy units

Providers working in outpatient hospitals, comprehensive outpatient rehabilitation facilities, and skilled nursing facilities frequently misreported and incorrectly billed for untimed therapy services, according to findings in the April Medicare Quarterly Provider Compliance Newsletter.

Medicare Recovery Auditors found that many claims for untimed therapeutic services were commonly billed with more than one unit of service, according to CMS. Specifically, the following codes were reported with more than one unit of service on the same day:

• CPT codes for special otorhinolaryngologic services and procedures such as: 
  • 92507, treatment of speech, language, voice, communication, or auditory processing disorder; individual
  • 92521, evaluation of speech fluency (e.g., stuttering, cluttering)
• CPT codes for physical therapy evaluations such as:
  • 97161, a physical therapy evaluation of low complexity
• CPT codes for occupational therapy evaluations such as:
  • 97165, occupational therapy evaluation of low complexity
• HCPCS codes for electromagnetic stimulation such as:
  • G0283, electrical stimulation (unattended) to one or more areas for indications other than wound care, as part of a therapy plan of care

As noted in the newsletter, providers use untimed HCPCS and CPT codes to bill for services that do not have specific time frames. Regardless of the time spent administering the service, providers can only bill one unit of untimed codes for a patient per date of service, with some exceptions.

CMS provides the following example: A provider wants to bill HCPCS untimed code 92521 for a speech-language pathology evaluation. Regardless of time spent administering this service, the provider may only bill one unit of service.

When reporting service units for most untimed codes where the procedure is not defined as an add-on code or by a specific timeframe, the provider should enter a 1 in the “units bill” column per date of service.

Per the Medicare Benefit Policy Manual, Chapter 15, Section 220.3, for outpatient rehabilitation therapy services, Medicare doesn’t require that unbilled services that are not part of the total treatment minutes be recorded, although they may be reported voluntarily to provide an accurate description of the treatment, or to comply with state or local policies.