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Coverage of Coverage of Therapeutic Therapeutic Recreation in Recreation in Clinical Settings Clinical Settings Tim Passmore, Ed.D., CTRS Tim Passmore, Ed.D., CTRS West Virginia Therapeutic West Virginia Therapeutic Recreation Association Annual Recreation Association Annual Conference Conference Oklahoma State University Oklahoma State University

Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

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Page 1: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Coverage of Coverage of Therapeutic Therapeutic

Recreation in Clinical Recreation in Clinical SettingsSettings

Tim Passmore, Ed.D., CTRSTim Passmore, Ed.D., CTRSWest Virginia Therapeutic West Virginia Therapeutic

Recreation Association Annual Recreation Association Annual ConferenceConference

Oklahoma State UniversityOklahoma State University

Page 2: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

What is Considered to be What is Considered to be Active Treatment by the Active Treatment by the Center for Medicare & Center for Medicare &

Medicaid Services (CMS)?Medicaid Services (CMS)?• Any intervention whichAny intervention which– RestoresRestores– Remediates Remediates – Rehabilitates Rehabilitates – ReducesReduces– Eliminates Eliminates

Page 3: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

What Settings Require What Settings Require Active Treatment?Active Treatment?

• Inpatient psychiatric servicesInpatient psychiatric services• Partial hospitalization servicesPartial hospitalization services• Inpatient Physical Rehabilitation Inpatient Physical Rehabilitation

servicesservices• Acute care servicesAcute care services• Public school systemsPublic school systems

Page 4: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Recreational Therapy Recreational Therapy Active TreatmentActive Treatment

• Therapeutic Recreation interventions that are functional in Therapeutic Recreation interventions that are functional in naturenature– … … standing X 10 minutes without assistance to complete table standing X 10 minutes without assistance to complete table

top leisure tasktop leisure task– Identify X 1 coping mechanism to assist with ….Identify X 1 coping mechanism to assist with ….– Ambulate X 175 within community…Ambulate X 175 within community…– What are some others????????What are some others????????

• Treatment session terminology Treatment session terminology – Community reintegration sessionsCommunity reintegration sessions– Life managementLife management– Task sessions – in place of arts & craftsTask sessions – in place of arts & crafts– Prescriptive therapy sessions – in place of exercise group, Prescriptive therapy sessions – in place of exercise group,

walking group, relaxation groupwalking group, relaxation group– Etc…Etc…

Page 5: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Recreational TherapyRecreational TherapyDiversional Activities/Non-Active Diversional Activities/Non-Active

TreatmentTreatment

• Recreation Activity/Diversional activityRecreation Activity/Diversional activity– DominoesDominoes– Movie nightMovie night– OutingsOutings– GolfGolf– Etc…Etc…

• There is therapeutic valueThere is therapeutic value– Just not covered by 3Just not covered by 3rdrd party Payors party Payors

• Maintenance and/or Palliative care!Maintenance and/or Palliative care!– Except in Long-term CareExcept in Long-term Care– Hospice Hospice

Page 6: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Who Makes Decisions Who Makes Decisions Regarding What Is a Regarding What Is a

Covered Service?Covered Service?Centers for Medicare & Medicaid ServicesCenters for Medicare & Medicaid Services

Fiscal IntermediariesFiscal Intermediaries

Quality Improvement OrganizationsQuality Improvement Organizations

Facility AdministratorsFacility Administrators

Departmental ManagersDepartmental Managers

Allied Health ProfessionalsAllied Health Professionals

ConsumersConsumers

Page 7: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Who Makes Decisions Who Makes Decisions Regarding What Is a Regarding What Is a

Covered Service?Covered Service?

• HCFA/HCFA/CMSCMS – Health Care Financing – Health Care Financing Administration/Administration/Centers for Centers for Medicare/Medicaid ServicesMedicare/Medicaid Services– Federal agencyFederal agency– Responsible for administration of Responsible for administration of

Medicare & MedicaidMedicare & Medicaid

• CMS – makes the rules/regulationsCMS – makes the rules/regulations

Page 8: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Who Makes Decisions Who Makes Decisions Regarding What Is a Regarding What Is a

Covered Service?Covered Service?• Intermediaries (FI) – (Medicare)Intermediaries (FI) – (Medicare)

– Process claimsProcess claims– Inpatient & outpatientInpatient & outpatient– Each state will have oneEach state will have one– Mediates disputes between hospitals and PROs Mediates disputes between hospitals and PROs – Issue Local Coverage Determinations (LCDs)Issue Local Coverage Determinations (LCDs)

• Quality Improvement Organizations formerly known as Peer Review Quality Improvement Organizations formerly known as Peer Review Organizations (PRO) – (Medicare) Organizations (PRO) – (Medicare) – Determine if a service is reasonable, necessary and provided in correct Determine if a service is reasonable, necessary and provided in correct

settingsetting– Each state has one Each state has one

• Administrators of Treatment FacilitiesAdministrators of Treatment Facilities– Directors ofDirectors of

• Activity TherapyActivity Therapy• Physical MedicinePhysical Medicine• Rehab Rehab • Principles/Teachers/ParentsPrinciples/Teachers/Parents

Page 9: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Fiscal IntermediaryFiscal Intermediary(FI)(FI)

• Most powerful entity outside of CMSMost powerful entity outside of CMS• System is changingSystem is changing• From FI to MACFrom FI to MAC

– Medicare Administrative Contractor (MAC) – Combined Medicare Administrative Contractor (MAC) – Combined management of Part A & Bmanagement of Part A & B

– First contract awarded First contract awarded • Noridian Administrative Services, LLC – Fargo NDNoridian Administrative Services, LLC – Fargo ND

– ArizonaArizona– MontanaMontana– North DakotaNorth Dakota– South DakotaSouth Dakota– UtahUtah– WyomingWyoming

• Noridian Administrative Services – has current statementNoridian Administrative Services – has current statement– Which would include Recreational TherapyWhich would include Recreational Therapy

• Next MAC contract will manageNext MAC contract will manage– Colorado, Oklahoma, New Mexico & TexasColorado, Oklahoma, New Mexico & Texas

Page 10: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Quality Improvement Quality Improvement OrganizationsOrganizations

• Cornerstone in efforts to improve Cornerstone in efforts to improve quality/efficiency of delivery of carequality/efficiency of delivery of care– Improve qualityImprove quality– Reduce improper payments for Reduce improper payments for

inpatient facilitiesinpatient facilities– Address beneficiary complaintsAddress beneficiary complaints– Mediation between healthcare Mediation between healthcare

providers and patientsproviders and patients

Page 11: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Administrators Administrators

• All are concerned withAll are concerned with– Generating dollarsGenerating dollars– Protecting dollarsProtecting dollars– Complying with regulationsComplying with regulations– Keeping their jobKeeping their job

Page 12: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

RegulationsRegulationsInpatient Psychiatric Inpatient Psychiatric

SettingSetting• Inpatient Psychiatric Facility (IPF)Inpatient Psychiatric Facility (IPF)• 20.1.2 – Services Expected to Improve the 20.1.2 – Services Expected to Improve the

Condition or for Purpose of Diagnosis, A3-Condition or for Purpose of Diagnosis, A3-3102.1.A.2, HO-212.1A2 of the Medicare Benefit 3102.1.A.2, HO-212.1A2 of the Medicare Benefit Policy ManualPolicy Manual Chapter 2. Chapter 2. – Specifically identified Recreational Specifically identified Recreational

Therapy/Therapeutic Recreation as an adjunctive Therapy/Therapeutic Recreation as an adjunctive therapytherapy

• Recreational Therapy & Occupational TherapyRecreational Therapy & Occupational Therapy– Replaced with the term Replaced with the term Therapeutic ActivitiesTherapeutic Activities– Per CMS communication did not alter the method of Per CMS communication did not alter the method of

payment for Recreational Therapy in a IPFpayment for Recreational Therapy in a IPF

Page 13: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Regulations – Inpatient Regulations – Inpatient Psychiatric Treatment Psychiatric Treatment

FacilitiesFacilities• ““If the only activities prescribed for If the only activities prescribed for

the patient are primarily diversional the patient are primarily diversional in nature, (i.e. to provide some in nature, (i.e. to provide some social or recreational outlet for the social or recreational outlet for the patient), it will not be regarded as patient), it will not be regarded as treatment to improve patients’ treatment to improve patients’ conditions.”conditions.”

Page 14: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

RegulationsRegulationsInpatient Physical Inpatient Physical

Rehabilitation Rehabilitation • Inpatient Physical Rehabilitation Facility Inpatient Physical Rehabilitation Facility

(IRF)(IRF)• 7 Screening Criteria for IRF7 Screening Criteria for IRF

– Close medical supervisionClose medical supervision– 24 hour rehabilitation nursing24 hour rehabilitation nursing– ““3-hour Rule” relatively intense level of 3-hour Rule” relatively intense level of

rehabilitation servicesrehabilitation services– Multidisciplinary teamMultidisciplinary team– Coordinated care programCoordinated care program– Significant practical improvementSignificant practical improvement– Realistic treatment goals & objectivesRealistic treatment goals & objectives

Page 15: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Inpatient Physical Inpatient Physical RehabilitationRehabilitation

• DEPARTMENT OF HEALTH AND HUMAN SERVICESDEPARTMENT OF HEALTH AND HUMAN SERVICESCenters for Medicare & Medicaid ServicesCenters for Medicare & Medicaid Services42 CFR Part 41242 CFR Part 412[CMS-1474-F][CMS-1474-F]RIN 0938-AL95RIN 0938-AL95Medicare Program; Changes to the Inpatient Rehabilitation Facility Prospective Payment System and Fiscal Medicare Program; Changes to the Inpatient Rehabilitation Facility Prospective Payment System and Fiscal Year 2004 RatesYear 2004 RatesPosted August 1, 2003Posted August 1, 2003

• Page 119Page 119• Intermediaries with respect to their scope of discretion, as well as, provide them with instructions to implement all Intermediaries with respect to their scope of discretion, as well as, provide them with instructions to implement all

revisions to the outlier policy contained in this final rule.revisions to the outlier policy contained in this final rule.

I. Miscellaneous CommentI. Miscellaneous CommentComment: Comment: We received a comment expressing a concern that some providers believe that recreational therapy services We received a comment expressing a concern that some providers believe that recreational therapy services are not covered by Medicare and that the costs of providing recreational therapy services are not included in the IRF are not covered by Medicare and that the costs of providing recreational therapy services are not included in the IRF PPS ratesPPS rates..

ResponseResponse: This comment is not specifically related to our proposed changes to the IRF PPS. We responded to similar : This comment is not specifically related to our proposed changes to the IRF PPS. We responded to similar comments in the IPPS January 3, 1984 final rule (49 FR 242) by stating that "comments in the IPPS January 3, 1984 final rule (49 FR 242) by stating that "Neither the implementation of the Neither the implementation of the prospective payment system nor the criteria for excluding certain hospitals and units from it will prohibit the provision prospective payment system nor the criteria for excluding certain hospitals and units from it will prohibit the provision of recreational therapy services to hospital inpatientsof recreational therapy services to hospital inpatients. In particular, the absence of these services from the list of . In particular, the absence of these services from the list of rehabilitative services in rehabilitation hospitals and units does not indicate that Medicare will no longer pay for them rehabilitative services in rehabilitation hospitals and units does not indicate that Medicare will no longer pay for them in those hospitals and units that provide them. in those hospitals and units that provide them. On the contrary, these services will continue to be covered to the same On the contrary, these services will continue to be covered to the same extent they always have been under the existing Medicare policies."extent they always have been under the existing Medicare policies." Since the publication of the January 3, 1984 final Since the publication of the January 3, 1984 final rule, we have not made any changes to our policies that would preclude recreational therapy services from those rule, we have not made any changes to our policies that would preclude recreational therapy services from those covered by Medicare. In particular the introduction of the IRF PPS does not change this fact.covered by Medicare. In particular the introduction of the IRF PPS does not change this fact. Accordingly, since Accordingly, since recreational therapy services were provided in the IRF base period, the costs of providing these covered services are recreational therapy services were provided in the IRF base period, the costs of providing these covered services are included in standardized payment amount upon which the IRF PPS rates are based”.included in standardized payment amount upon which the IRF PPS rates are based”.

• Figure 7.1 – Department of Human Services – Centers for Medicare & Medicaid Services – 42 CFR Part 412 [CMS-Figure 7.1 – Department of Human Services – Centers for Medicare & Medicaid Services – 42 CFR Part 412 [CMS-1474-F] RIN 0938-AL951474-F] RIN 0938-AL95

Page 16: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

The Term RecreationThe Term Recreation

• Recreational Therapy/Therapeutic Recreational Therapy/Therapeutic Recreation Recreation – Often not given similar consideration asOften not given similar consideration as

• Other allied health professionOther allied health profession• Because of the term recreationBecause of the term recreation

• RegulationsRegulations– Specifically state – don’t not pay or cover Specifically state – don’t not pay or cover

• RecreationRecreation• DiversionDiversion• Maintenance Maintenance • Comfort Comfort

Page 17: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

How Do I Establish the How Do I Establish the Framework for Coverage of Framework for Coverage of

ServicesServices• Become familiar with state and federal Become familiar with state and federal

regulations regulations – Based on treatment settingBased on treatment setting

• Familiarize self with Professional Familiarize self with Professional Standards of PracticeStandards of Practice

• Know who your 3Know who your 3rdrd Party Payors Party Payors – MedicareMedicare– MedicaidMedicaid– Insurance companiesInsurance companies

• Administrative support at the facility levelAdministrative support at the facility level

Page 18: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Steps to Obtaining Steps to Obtaining CoverageCoverage

• Physician’s OrdersPhysician’s Orders• AssessmentAssessment• Goals & ObjectivesGoals & Objectives• Treatment PlanTreatment Plan• Delivery of Services or InterventionsDelivery of Services or Interventions• Documentation of Provision of Documentation of Provision of

Services/InterventionsServices/Interventions• ReevaluationReevaluation• Discharge Recommendations & Summary Discharge Recommendations & Summary

Page 19: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Steps to Obtaining Steps to Obtaining CoverageCoverage

• Follow the Therapeutic Recreation Follow the Therapeutic Recreation ProcessProcess– Assessment Assessment – PlanningPlanning– ImplementationImplementation– EvaluationEvaluation

Page 20: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Formula for Establishing Formula for Establishing Unit ChargesUnit Charges

• Salaries & BenefitsSalaries & Benefits $2,032,800$2,032,800• Operational ExpenseOperational Expense $ 209,440$ 209,440• Administrative/Clerical SupportAdministrative/Clerical Support $ 656,000$ 656,000• SubtotalSubtotal $2,898,240$2,898,240• Overhead @ 40%Overhead @ 40% $1,159,296$1,159,296• Total CostsTotal Costs $4,057,536$4,057,536• Cost per hour of patient careCost per hour of patient care: (Divide total cost by number of : (Divide total cost by number of

hours of patient care)hours of patient care)• $4,057,536 Total Cost/Year divided by 20,000 Hours of Patient $4,057,536 Total Cost/Year divided by 20,000 Hours of Patient

Care/Year = $202.88/HourCare/Year = $202.88/Hour• Cost per unit of patient careCost per unit of patient care: (Divide cost per hour by 15 min : (Divide cost per hour by 15 min

[or unit time] equals dollars per 15 min unit charge) $202.88/4 = [or unit time] equals dollars per 15 min unit charge) $202.88/4 = 50.74 per unit or 15 minutes50.74 per unit or 15 minutes

• *Overhead is calculated at 40 percent of direct costs. It includes *Overhead is calculated at 40 percent of direct costs. It includes various indirect expenses such as heating/cooling, electric, various indirect expenses such as heating/cooling, electric, printing, maintenance, and housekeeping.printing, maintenance, and housekeeping.

Used by Permission: Carter, Van Andel, & Robb – Waveland Press, Used by Permission: Carter, Van Andel, & Robb – Waveland Press, INC.INC.

Page 21: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

SubjecSubject: t: Systematic Handling Systematic Handling of Unit Chargesof Unit Charges

PolicyPolicyThe Recreational Therapy Department will record daily unit charges prior to leaving The Recreational Therapy Department will record daily unit charges prior to leaving

the the treatment facility at the noon hour and at the end of the day. Time allocation for treatment facility at the noon hour and at the end of the day. Time allocation for triggering unit recording will consist of more than 1 minute spent with a patient of triggering unit recording will consist of more than 1 minute spent with a patient of

this this treatment facility will equal 1 unit charge. treatment facility will equal 1 unit charge.

ProcedureProcedureRecreational Therapists will record unit charges in 15 minute increments Recreational Therapists will record unit charges in 15 minute increments utilizing the unit charge slips in the appropriate charge category.utilizing the unit charge slips in the appropriate charge category.

Recreational Therapists will record 1, 2, or appropriate numeric unit charge Recreational Therapists will record 1, 2, or appropriate numeric unit charge representing time allocation per patient to represent time spent providing active representing time allocation per patient to represent time spent providing active treatment.treatment.

Recreational Therapists will sign and date unit charge slips on a daily basis.Recreational Therapists will sign and date unit charge slips on a daily basis.

Recreational Therapists will turn in completed unit charge slips to rehabilitation Recreational Therapists will turn in completed unit charge slips to rehabilitation technician technician

prior to final departure from treatment facility.prior to final departure from treatment facility.

Page 22: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Subject: Unit ProductivitySubject: Unit ProductivityPolicyPolicyThe Recreational Therapy Department will calculate daily The Recreational Therapy Department will calculate daily productivity by tallying daily treatment facility unit charges. productivity by tallying daily treatment facility unit charges. Each Recreational Therapist will be responsible for a Each Recreational Therapist will be responsible for a minimum daily productivity level of 24 units.minimum daily productivity level of 24 units.

ProcedureProcedureThe rehabilitation technician will tally the actual daily The rehabilitation technician will tally the actual daily productivity level of each recreational therapist.productivity level of each recreational therapist.

The rehabilitation technician will record the daily The rehabilitation technician will record the daily productivity level of each recreation therapist in the productivity level of each recreation therapist in the productivity log book.productivity log book.

Page 23: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Medicare Part A & BMedicare Part A & B• Medicare Part A – has regulatory Medicare Part A – has regulatory

governance governance – Inpatient hospitalsInpatient hospitals– Critical access hospitalsCritical access hospitals– Skilled nursing facilitiesSkilled nursing facilities– Some home health Some home health – HospiceHospice

• Medicare Part B – has regulatory Medicare Part B – has regulatory governancegovernance– PhysiciansPhysicians– Specific medically necessary servicesSpecific medically necessary services– Home healthHome health– Outpatient hospital careOutpatient hospital care

Page 24: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Prospective Payment Prospective Payment SystemSystem

• Based on Diagnostic Related Groups Based on Diagnostic Related Groups (DRGs)(DRGs)

• Payment based on groupings of Payment based on groupings of diagnosisdiagnosis– Adjusted related location within USAAdjusted related location within USA

Page 25: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Prospective Payment Prospective Payment SystemSystem

• AreasAreas– Inpatient Physical Rehabilitation Inpatient Physical Rehabilitation

Facilities (IRF - PPS)Facilities (IRF - PPS)– Inpatient Psychiatric Facilities (IPF - Inpatient Psychiatric Facilities (IPF -

PPS)PPS)– Long-term Care Facilities (LCT - PPS)Long-term Care Facilities (LCT - PPS)

• DID NOT CHANGE MEDICARE DID NOT CHANGE MEDICARE REGULATIONSREGULATIONS

Page 26: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Local Coverage Local Coverage DeterminationsDeterminations

LCDLCD• IRF – LCD which include RT/TR in the “3-IRF – LCD which include RT/TR in the “3-

hour Rule”hour Rule”– AdminaStar FederalAdminaStar Federal

• IL, IN, OH, KYIL, IN, OH, KY

– AnthemAnthem• NH, VT, MA, MENH, VT, MA, ME

– First Coast ServiceFirst Coast Service• FLFL

– TriSpan Health ServicesTriSpan Health Services• LA, MO, MSLA, MO, MS

– Noridian – no LCD but a statementNoridian – no LCD but a statement• AK, MN, ND, WA, WY, AZ, Montana AK, MN, ND, WA, WY, AZ, Montana

Page 27: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Local Coverage Local Coverage DeterminationsDeterminations

LCDLCD• IPF – LCD which include RT/TR as active IPF – LCD which include RT/TR as active

treatmenttreatment• Most LCDs – Inpatient Most LCDs – Inpatient

psychiatric/Partial Hospitalization/Day-psychiatric/Partial Hospitalization/Day-treatment Facilitiestreatment Facilities– Which are manyWhich are many– Continue to utilize the old language of Continue to utilize the old language of

specifically mentioning/including specifically mentioning/including Recreational Therapy/Therapeutic Recreational Therapy/Therapeutic RecreationRecreation

Page 28: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

IRF – LCD which include IRF – LCD which include RT/TR in the “3-hour Rule”RT/TR in the “3-hour Rule”

• Most state the followingMost state the following– Provided under an individualized treatment or Provided under an individualized treatment or

diagnostic plan;diagnostic plan;– Reasonably expected to improve the patient’s Reasonably expected to improve the patient’s

condition or for the purpose of diagnosis; andcondition or for the purpose of diagnosis; and– Supervised and evaluated by a physicianSupervised and evaluated by a physician

• Most state “Recreation is a Non-Covered Most state “Recreation is a Non-Covered Service” – meaning diversional/recreational Service” – meaning diversional/recreational activates are not a covered itemactivates are not a covered item

• Is not referring to Recreational Therapy Is not referring to Recreational Therapy – Which is active treatment – not the provision of Which is active treatment – not the provision of

recreationrecreation

Page 29: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

CPT CodesCPT Codes• ••97110 – Therapeutic Procedure, each 15 min. therapeutic exercise to 97110 – Therapeutic Procedure, each 15 min. therapeutic exercise to

develop strength & endurance, ROM and flexibilitydevelop strength & endurance, ROM and flexibility• ••97112 – Neuromuscular reeducation of movement, balance, 97112 – Neuromuscular reeducation of movement, balance,

coordination, kinesthetic sense, posture and proprioceptioncoordination, kinesthetic sense, posture and proprioception• ••97530 – Therapeutic activities – direct 1 to 1 patient contact provider 97530 – Therapeutic activities – direct 1 to 1 patient contact provider

(use of dynamic activities to improve functional performance(use of dynamic activities to improve functional performance• ••97113 – Aquatic therapy with therapeutic exercise97113 – Aquatic therapy with therapeutic exercise• ••97150 – Therapeutic procedure – group (2 or more individuals up to 4 97150 – Therapeutic procedure – group (2 or more individuals up to 4

with one TR)with one TR)• ••97532 – Development of cognitive skills to improve attention, memory, 97532 – Development of cognitive skills to improve attention, memory,

problem solving, problem solving, • ••97533 – sensory integrative techniques to enhance sensory processing 97533 – sensory integrative techniques to enhance sensory processing

and promote adaptive responses to environmental demandsand promote adaptive responses to environmental demands• ••97535 – Self care/home management training (ADL & compensatory 97535 – Self care/home management training (ADL & compensatory

training, meal preparation, safety procedures, instructions in use of training, meal preparation, safety procedures, instructions in use of adaptive equipment)adaptive equipment)

• ••97537 – Community/work reintegration training (shopping, 97537 – Community/work reintegration training (shopping, transportation, money management, avocational activities and/or work transportation, money management, avocational activities and/or work environment/modification analysis, work task analysisenvironment/modification analysis, work task analysis

• 97542 – Wheelchair management/propulsion97542 – Wheelchair management/propulsion

Page 30: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Test a CPT CodeTest a CPT Code

• https://catalog.ama-assn.org/Cataloghttps://catalog.ama-assn.org/Catalog/cpt/cpt_search.jsp?_requestid/cpt/cpt_search.jsp?_requestid=770140=770140

Page 31: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Letters From HCFA/CMS Letters From HCFA/CMS to ATRAto ATRA

• “…“…while specific recognition of while specific recognition of recreational therapy is not given in the recreational therapy is not given in the instructions, there is nothing that would instructions, there is nothing that would preclude the coverage of recreational preclude the coverage of recreational therapy when appropriate. Moreover, therapy when appropriate. Moreover, there is specific language in the manual there is specific language in the manual which indicates that alternatives to which indicates that alternatives to physical therapy and occupational therapy physical therapy and occupational therapy may be covered when needed as may be covered when needed as appropriate.” (Hoyer, 1994)appropriate.” (Hoyer, 1994)

Page 32: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Letters From HCFA/CMS Letters From HCFA/CMS to ATRAto ATRA

• “…“…requires inpatient hospital rehabilitation requires inpatient hospital rehabilitation services may need, on a priority basis, other services may need, on a priority basis, other skilled rehabilitation modalities such as speech-skilled rehabilitation modalities such as speech-language pathology services or prosthetic language pathology services or prosthetic orthotic services. In such cases, the three hours orthotic services. In such cases, the three hours a day requirement can be met by a combination a day requirement can be met by a combination of these other therapeutic services instead of, or of these other therapeutic services instead of, or in addition to, physical therapy and/or in addition to, physical therapy and/or occupational therapy. An inpatient stay for occupational therapy. An inpatient stay for rehabilitation care can also be covered even rehabilitation care can also be covered even though the client has a secondary diagnosis or though the client has a secondary diagnosis or medical complication that prevents him from medical complication that prevents him from participating in a program consisting of three participating in a program consisting of three hours of therapy a day.” (Hoyer, 1994)hours of therapy a day.” (Hoyer, 1994)

Page 33: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

LMRPs / LCDsLMRPs / LCDs

• LMRP = Local Medical Review LMRP = Local Medical Review PolicyPolicy

• LCD = Local Coverage LCD = Local Coverage DeterminationDetermination

Page 34: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Introduction From ATRA Executive Director8-1-03 Medicare and Recreational Therapy News Release 8-1-03 Excerpt, 42 CFR, Part 412, Page 19: Medicare Program; Changes to the Inpatient Rehabilitation Facility Prospective Payment System and Fiscal Year 2004 Rates 04-04-00 HCFA Correspondence02-18-00 ATRA Legislative Counsel Letter07-20-94 American Rehabilitation Association Tech Brief12-23-93 HCFA Correspondence with Enclosure08-22-89 HCFA PRO Correspondence08-86 Medicare Hospital Manual Transmittal No. 491

ATRA 3-Hour Rule DocumentsATRA is pleased to provide the following documents for the ATRA member(s) to use in advocating for active

treatment recreational therapy services in inpatient rehabilitation settings. For additional information on interpretation and use of these documents, please contact the ATRA National Office at (703) 683-9420 or the

Coverage and Reimbursement Team Leaders through the contact information on the Team Leadership Directory http://www.atra-tr.org/teamleader.htm

Page 35: Coverage of Therapeutic Recreation in Clinical Settings Tim Passmore, Ed.D., CTRS West Virginia Therapeutic Recreation Association Annual Conference Oklahoma

Contact InformationContact Information

Tim Passmore, Ed.D., CTRSTim Passmore, Ed.D., CTRSAssistant ProfessorAssistant Professor

School of Applied Health & School of Applied Health & Educational PsychologyEducational Psychology

Leisure Studies ProgramLeisure Studies ProgramOklahoma State UniversityOklahoma State [email protected]@okstate.edu

(405) 744-1811(405) 744-1811