By Lori O’Hara, MA, CCC-SLP – Therapy Resource,  ADR/Appeals/Clinical Review

CMS doesn’t define a lot of requirements for what needs to be in a daily note, understanding that it’s what happens during the session that drives the content. But one of the places where they do define a requirement is on the day of the evaluation. Because evaluation minutes don’t count towards the calculation of a RUG score, but treatment minutes do count, they want to be able to see easily that those things were different when they occur on the same day. That means a narrative entry is always required when treatment occurs on the day of the evaluation.

What needs to be in the note? Content that describes how activity billed to the treatment codes was clearly not activity that should have been billed to the evaluation code. So the content in the therapy CPT boxes should describe skilled activity associated with the specific treatment code being billed.

Content that is providing detail on the evaluation findings, interpreting scores or risks associated with testing performance with the patient or family, or describing goal setting is evaluation related. So this cannot be billed towards a therapy code and should not be documented in therapy CPT boxes.

Education about the patient’s conditions or limitations, trialing devices or attempting environmental adaptations, and specific therapeutic interventions are treatment related and should be billed to and recorded as their corresponding CPT codes. Content should be detailed enough that it’s evident to anyone reading that those activities were clearly distinct from the evaluation activity.

Reviewers are starting to look for this – managed care organizations too!  So, protect your minutes on your evaluation day content that is just as amazing as the services you provide.