As of October 1, 2013, providers must capture the total number of therapy co-treatment minutes provided in the last seven days by discipline in the new MDS items (O0400A3A, O0400B3A and/or O0400C3A) and many providers are beginning to seek clarification regarding whether facilities still get paid for these minutes.

The answer is Yes—IF you capture the co-treatment minutes twice per discipline in order to be appropriately reimbursed:

• Once as appropriate in section O0400A3A, (speech-language pathology and audiology services co-treatment minutes), O0400B3A (occupational therapy co-treatment minutes), and O0400C3A (physical therapy co-treatment minutes) for data collection; and
• A second time to capture RTMs (reimbursable therapy minutes) in corresponding item for individual minutes for the appropriate therapy mode (e.g., O0400A1-speech language pathology and audiology services, O0400B2-occupational therapy, or O0400C1)

The Centers for Medicare and Medicaid Services (CMS) has confirmed that minutes delivered in co-treatment sessions till count as reimbursable therapy minutes for Medicare Part A patients.  Unfortunately, the coding instructions for entering co-treatment minutes in Chapter 3, page O-17 of the RAI Users Manual could be misinterpreted and lead providers to make false assumptions about how to capture these minutes as RTMs.   However, the OTA and PT sections of the general coding example provided by CMS on pages O-28 through O-30 do illustrate the need to capture the same co-treatment minutes in two separate, distinct MDS items per discipline.

So provider beware—do not assume everyone responsible for data entry on the MDS in your facility has this understanding.   Taking time to review coding of co-treatment minutes with your staff can prevent unnecessary loss of revenue in this day and time when every penny counts!