Plan of Care vs Progress Note

Our #1 priority for Netsmart TheraOffice has always been to keep your physical therapy practice running smoothly and allow you to worry less about regulation and focus more of your time on providing the best care for your patients. However, between CMS’ rules surrounding the Plan of Care and the entirely different set of regulations on Progress Notes, we understand that the rules can be difficult to keep track of.

Netsmart has built TheraOffice, our physical therapy EMR software with two handy tools to track each of these components separately to increase your clinic’s accuracy. We recommend using Document Reminders to track your plans of care. For Progress Notes, we have built a handy alert for you that will notify your front desk to change the appointment type to a Progress Visit upon the patient’s 10th visit.

Plans of Care for Physical Therapy

Thanks to direct access laws, in many states, getting paid for Medicare patients is easier than ever. However, if you are in one of the 32 states with provisions on or limited access, the Plan of Care requirements can be a significant barrier to payment. Here are a few things to keep in mind to keep your regular Medicare payments flowing.

Writing a Physical Therapy Plan of Care

Plans of Care are created specifically for each patient based on information provided to the therapist during their evaluation of the patient. According to the APTA, these plans should include “at minimum: (1) diagnoses; (2) long-term treatment goals; and (3) type, amount, and duration of therapy services.” But, you may also want to include short term goals and discharge plans to make the plan more meaningful to the patient as well as the providers.

PT Plan of Care Certification

Once the Plan of Care for the patient has been written, the therapist must then get the Plan of Care certified by having it reviewed by a physician or NPP. “Since payment may be denied if a physician does not certify the plan,” this should occur as soon as possible to ensure that it is returned within 30 days of the initial therapy treatment.

The physician must then sign and return the Plan of Care to the physician. This signature on the Plan of Care must also be dated and, while it can be either a pen-and-paper or electronic signature, it cannot be a stamp. Interestingly, Medicare does not require the physician to have seen the patient to certify the plan, but keep in mind that some physicians have a policy in place mandating a visit.

Once signed, the physical therapist is certified to treat the patient for the duration of time laid out in the Plan of Care, until the patient’s condition dramatically changes and “requires revision of long-term goals”, or 90 days after the initial treatment—whichever happens first. At that point, if the patient still requires care, the physical therapist must get recertified by submitting a new Plan of Care and going through the process again.

Physical Therapy Progress Notes

Progress notes, by contrast, are used to justify medical necessity. These notes, while still required by Medicare, do not require outside review and have no bearing on a patient’s certification.

Instead, Progress Notes are used to establish three key things:

• Objective measurements which provide evidence to show the patient’s condition creates limitations in their life. (Functional Status)
• These limitations can be improved upon or their progress can be maintained through physical therapy. (Goals)
• The achievement of these goals requires the skills, expertise, and clinic judgements of a physical therapist.

These notes are required every 10 visits, and, as CMS stresses, the “dates of recertification of plans of care do not affect the dates for required Progress” notes. That said, if you do a Progress Note and realize that your Plan of Care no longer fits the patient’s needs, you should generate a new POC from the note and get it recertified as soon as possible.

Note: The guidelines presented in this article are from APTA and CMS Resources. However, it is always advisable to check your individual State Practice Act, as these may be more restrictive than federal guidelines.