The Medicare Benefit Policy Manual Chapter 16, Section 220 Refers to Coverage of Outpatient Rehabilitation Therapy Services (Physical Therapy, Occupational Therapy, and Speech-Language Pathology Services) Under Medical Insurance. In addition to the requirements described in this chapter, the services must be furnished in accordance with health and safety requirements set forth in regulations at 42CFR484, and 42CFR485.

These regulations reference verbal orders and authentication of orders, specifically found in the Centers for Medicare & Medicaid Services: 42 CFR Parts 482 and 485 Final Rule Effective July 16, 2012 as follows:

• Verbal Orders: The requirement for authentication of verbal orders within 48-hours has been deferred to applicable State law to establish authentication timeframes
• Authentication of Orders: The temporary requirement that all orders, including verbal orders, must be dated, timed, and authenticated by either the ordering practitioner or another practitioner who is responsible for the care of the patient and who is authorized to write orders by hospital policy in accordance with State law has been made permanent

Why Is This Important?   Third party Medicare reviewers (MACS, ZPICS, RACS) have been citing these regulations as a basis for denying claims.   Therefore, it is crucial that facility policies regarding verbal orders and authentication of orders be reviewed and updated and these regulations and policies be shared with the medical staff to ensure claims will be paid and not denied on the basis of these coverage criteria.  Processes should be developed to ensure the policies are followed and someone should be designated to assume responsibility for compliance with the regulation and facility policy.