LOL—Yes they are mints if you are looking to improve your breath but these days, we as an industry are just trying to catch our breath!

A “CERT” stands for ‘Community Emergency Response Team’ if you are referring to first aid products or ‘Computer Emergency Readiness Team’ if you are referring to improving the nation’s cybersecurity posture, and it is short for ‘certification’.  I am sure you would agree that there are many others out there or we could be innovative and come up with our own. But the ‘CERT’ I want to talk about refers to Comprehensive Error Rate Testing.  How does a CERT relate to therapy documentation?  Let’s take a look…

CMS developed the CERT program in order to produce a national fee for service error rate.  The CERT Program errors relate to outpatient therapy services and provides information on the documentation that is needed to support a therapy claim.

How does this work you ask?  Well the CERT will randomly select small samples of claims then requests documentation to review compliance with Medicare coverage, coding, and billing rules.

Common errors identified through the CERT review process are:

  • Missing/incomplete plan of care/plan of treatment
  • Missing physician signatures and dates
  • Missing total time for procedures and modalities
  • Missing certification and recertification

So how do you avoid a CERT error?  Great question!  But do you really want the answer?  Unfortunately, the way to avoid a CERT error is to review your documentation and billing practices!  I know… that isn’t very exciting and frankly can be extremely boring!  So when you sit down to review have plenty of coffee or espresso, or if you are not a coffee drinker, Mountain Dew is a good choice.  But in all seriousness, it is extremely important to review your therapy documentation frequently as well as therapy billing practices. 

Tips to help avoid a CERT error:

  1. Make sure your therapists are creating a complete plan of care/plan of treatment which includes the therapist’s signature, professional credentials, and the date the plan was established
  2. Make sure therapists are documenting why the previous goals were not met or could not be met to support the modification of the plan
  3. Make sure the plan of care/plan of treatment has been certified by the physician–physician’s legible signature and date
  4. Make sure the therapists/assistants are clearly documenting to support the therapy minutes billed
  5. Make sure the treatment minutes are clearly documented in the patients record; ensure time and untimed codes are billed appropriately

If you receive a CERT review, please inform your therapy provider and provide therapy with the CERT letter.  The CERT will provide you with documentation tips that you should take seriously.  Therapy teams should in-service staff based off the CERT tips page and in conjunction with the therapy provider’s compliance department, develop action plan items to decrease provider risk.

With all of the scrutiny our industry is under, we welcome documentation tips and advice on how to avoid errors and decrease risk.  Our industry  may not be able to catch our breath all the time but when you partner with a proactive therapy provider, you will be able to breathe much easier!

Gina Tomcsik

Director of Compliance

Functional Pathways