This guide is designed to provide you with valuable information and guidelines on Luna’s management of state Direct Access laws, Medicare Plan of Care requirements, and other compliance-related topics.
For assistance with direct access, plan of care, or other compliance inquiries, please create a ticket in the Clinical channel.
Sections
2. Medicare Plan of Care Management
3. Caregiver Training without the Patient
1. Direct Access Management
How do I know my patient is Direct Access?
- If your patient does not have a referral on file under “manage documents” in the app, it is safe to assume that they are being seen under Direct Access
Where can my patient view the Direct Access law for their state?
- Patient’s can review the requirements for their state by viewing Luna’s terms of use, https://www.getluna.com/terms-of-use
- Referrals and physician information are not required to start care with Luna.
- Once the patient starts approaching the Direct Access threshold for their state, the Compliance team will gather physician information and the required referral/signed POC to continue care.
How are POCs sent? Do I need to contact the physician?
- Luna handles all Physician communication for you.
- Based on the state’s Direct Access guidelines,
- a POC will automatically be faxed to the physician on file
- Luna’s Compliance team follows up to obtain the signed POC/referral
- Last Progress Visits are usually sent to gather approval for Ongoing visits. Therapists should ensure Progress Visits have the most up to date information.
How do I know when my patient is approaching Direct Access violation and now needs a referral?
- Luna’s Compliance team messages you if:
- A referral or POC is not signed and the Direct Access timeline is approaching OR
- The physician did not approve ongoing care and wants to see the patient back in the office.
- The message includes the date after which Direct Access is not allowed.
- If the referral/signed POC is not obtained by that date, care will need to be discontinued.
- Therapists are responsible for communicating with patients and start discharge planning with patients in case a referral or signed POC is not received in time.
What happens when a patient exceeds the Direct Access timeline?
- If Patient reaches the Direct Access threshold and if Luna has not yet received a signed POC or referral,
- Ongoing care is not allowed.
- Therapists will be reminded/messaged in the app when the patient has reached the Direct Access threshold for their state.
- All future scheduled visits will be canceled and scheduling disabled.
- With therapist approval, the patient can complete 1 last visit to complete discharge instructions and complete care.
2. Medicare Plan of Care Management
Can I treat a Medicare patient without a referral or signed POC?
- Referrals are not needed to initiate care.
- Medicare requires that a POC be signed at the initial visit and for every progress visit within 60 days of the initial visit date.
- Visits can still be scheduled and completed while the team works to gather the signed POC.
How are POCs sent? Do I need to contact the physician?
- Luna handles all Physician communication for you.
- After the first visit, and every 10 visits, a POC will automatically be faxed to the physician on file for signature.
- Luna’s compliance team regularly contacts the physician’s office to obtain the signed POC prior to the 60 day threshold established by Medicare.
How do I know when my patient is approaching Medicare violation and now needs a signed POC?
- Luna’s compliance team will message you in the app to notify you that we are still working to obtain the POC.
- The message will include the date that the patient will violate Medicare’s POC guidelines and notify you that care will potentially be discontinued if not received.
What happens when a patient exceeds Medicare’s 60 day threshold?
- Luna’s compliance team will send a follow up message in the app notifying you that the patient has reached the 60 day limit with no POC signed.
How can therapists or patients support this process?
- At that time, all future scheduled visits will be canceled and scheduling disabled.
- Communicate the need for signed POC/referral to the patient after the warning message is received.
- Advise the patient to contact their physician for the signed POC.
3. Caregiver Training without the Patient
Who is considered a caregiver?
- CMS defines a caregiver as: “one who provides unpaid assistance to a person with a chronic illness or disabling condition and is in a position to assist the patient in carrying out an established treatment plan or plan of care.”
- This can be an adult family member, neighbor, friend, or other individual with a significant relationship to the patient.
What is considered caregiver training?
- Patient present - Caregiver training is usually performed with the patient present. In this case, standard CPT codes of The Act, Self Care / Home Management can be used.
- Patient not present - Caregiver training in the absence of the patient is to be used in specific instances and is considered a deviation from standard procedure. The new CPT codes 97550 & 97551 are used for Caregiver training in the absence of the patient.
- CMS defines the code as “Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem solving, safety practices) (without the patient present).
- Training must coincide with the treatment plan and be designed to achieve desired patient outcomes.
- Consent is required from the patient or, if applicable, the patient’s representative for a caregiver to receive caregiver training services.
- The special consent for caregiver training must be documented in the patient’s medical record. Consent to treat is not sufficient as per CMS.
- Training must be conducted face-to-face, these codes cannot be used for virtual/telehealth visits.
Billing guidelines:
- 97550 and 97551 are the 2 codes approved by CMS for Caregiver training.
- 97550: first 30 minutes of caregiver training
- can be used once during the care plan and used during any visit when caregiver training is conducted for the first time.
- minimum of 15 mins needed to bill for 97550.
- 97551: additional 15 mins of caregiver training
- time spent over initial 30 mins should be billed under 97551
- minimum of 8 mins needed for 1 unit of 97551
- Multiple caregivers for one patient can attend a training session, billing for the code is based on time spent and not billed for each caregiver individually.
4. Health and Safety Policy
At Luna, we prioritize the well-being of our providers and the communities we serve. In markets where special instructions from hospital partners are applicable, Luna takes additional measures to ensure the highest standards of flu prevention precautions. Our commitment to a healthy environment is reflected in the following policies:
Annual Flu Prevention Awareness:
- Luna's providers receive annual notices in October, emphasizing the importance of flu prevention measures.
- Providers are expected to be diligent about the following precautions:
- Frequent hand washing
- Vaccination
- Staying home if experiencing flu-like symptoms
Notification of Flu Symptoms:
- If a provider suspects they may have the flu, it is mandatory to notify Luna promptly.
- Upcoming patient care visits are to be rescheduled to prevent potential transmission.
Adherence to Flu and Covid Guidelines:
- Providers are required to follow current flu and Covid guidelines for a safe return to work.
- In accordance with state and national guidelines, a provider may not return until 24 hours after the resolution of fever.
Communication of Illness:
- Luna providers should contact Luna via in app chat to notify of any illness promptly.
This policy underscores Luna's commitment to maintaining a healthy working environment, safeguarding both our providers and the individuals under their care. By adhering to these guidelines, we contribute to the overall well-being of our community and fulfill our mission to provide exceptional healthcare services.
