OH--Individual

-- OTs are NOT Cash Cows! -- Whoever heard of a G & A charge of 300%?! Dear Regulators and Therapists: In regards to "concurrent therapy", I have found the proposed content and comments to be quite amazing. At present, there is no such billing category, but here we see therapists and administrators openly admitting to the practice. Medicare seems to have let itself be fooled. Medicare billing allows for two things: Group or individual, with some ability to treat two patients at one time. As it is being implemented, "concurrent" is neither. Therefore, all practitioners of this are simply and directly committing Medicare Fraud. Why should these people and organizations, promoting unethical, substandard and illicit practices; being rewarded by having this unrecognized and unsbustantiated practice made respectable? Fact: 1. "Concurrent Therapy" is rarely remotely the same thing as real therapy. Fact: 2. "Concurrent" Therapy is a nonsense word. Fact: 3."Concurrent Therapy" does not help the staffing situation, far from it. Its practices artificially drive the insanity to ever higher RUG rates, and inappropriate and useless procedures. Fact: 4. The claim is made that "concurrent therapy" helps control staffing costs, and eliminating it will make the staffing crisis worse. Nonsense! It is the inherently anti-professional, concurrent non-therapy, forced march, high "productivity", assembly line mentality which forces real clinicians and the best therapists out of working in SNFs. It is not the solution, but the problem. Fact: 5. There is no evidence to support the practice, so it is virtually unethical to promote it. Fact: 6. There has been no research to prove that the MDS system, which is based on the erroneous belief that by overfunding and over-reimbursing therapy costs, one can drive better outcomes, is beneficial. What to do? - Hold the line, and only allow either individual or group treatment. - Vigorously enforce against practitioners bilking the patients and Medicare by the fraudulent practice of pretending that it is reasonable to claim that one can treat 4 patients with different skilled needs at the same time. I urge the therapists reading this to stand up and organize to not allow "concurrent therapy" to be legalized. Tell the administrators to stop holding us hostage, and to stop demanding 300 to 400% G & A overhead. To Medicare and the supporters of our seniors: Stop pushing so much money at SNFs which allege to provide much service. It is counter productive and is corrupting the therapies. Thank you. Sincerely, Lise Rubin, M.Ed., OT/L