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An Apple a Day


Take the pain out of your rehabilitation marketing.

By Brandon Moser

If you have a chance, look at some health industry advertisements. Do you see a difference in their visual marketing? It should come as no surprise that they are similar—a lot of toothy grins from 30-somethings; slightly graying yet attractive women gardening; guys on bikes; and dream teams of confident health care professionals standing together (including a guy with his arms folded, wearing scrubs, and a lady wearing glasses and in a lab coat while carrying a clipboard). Oh, and do not forget the apples. Apples always mean a healthy lifestyle.

Before I entered the marketing and advertising world 20 years ago, I was a physical therapy practitioner. I had some great patients that took their home exercises seriously. I also had patients who constantly complained their rehabilitation was not happening quickly enough. When the patient was pushed for details, it was evident they were not doing the necessary effort outside of the clinic to recover as fast as they hoped. There are similarities in marketing.

Health care providers often take shortcuts in their marketing and promotion. Then they are unsatisfied with the results. There are no shortcuts in rehabilitation—and there are no shortcuts in creating effective, revenue-producing marketing.

Cheap can be very expensive
I wish I had a nickel for every time we had a new customer come to us with a story about how they were disappointed by someone who had designed a terrible marketing piece for them. After further questioning, I usually found it was a result of the customer giving the business to the lowest-possible bidder.

The growth of your business, and your livelihood, depends on successful, effective marketing. And yet cost is always one of the biggest drivers in marketing decisions. Do not be cheap here. Be smart, because “You get what you pay for.” It is true. You also get what you do not pay for—such as stress, inferior quality, and dealing with more daily pain than a torn triceps surae muscle. Because if they are charging next to nothing, it means that they have next to nothing to offer. It does not mean spend indiscriminately. You do not need Don Draper to write your jingle. Just spend intelligently. And sometimes a little more than you may be comfortable with.

The truth is that solid, evidence-based marketing from industry experts will usually pay for itself and then some. If you choose the right marketing partner, with the right skill set, cost should never be an issue. You will be concentrating on bottom-line revenue potential rather than short-term costs. Being cheap with marketing dollars is an ailment for which there is no cure.

If you do not stand out, you do not stand a chance
The health industry has traditionally been very conservative in their marketing efforts. Whether it is due to past regulatory intimidation or just becoming creatively lazy due to the conservative nature of the health care industry, it provides an enormous opportunity for those who want to stand out from the crowd.

If you ever wonder why the response rates are low for your advertising, take a good hard look at your creative. Take a look at the images you are using. Are they different from the competition? Or are you walking along the same beaches, frolicking in the same parks, and gardening with the same slightly graying, attractive ladies? Are you overemphasizing the importance of representing all ethnicities to your audience at the expense of decreasing the emotional pull it may have with your audience?

Instead of using emotionally stirring imagery that truly tells the story of the organization’s brand, the pictures are spiritless and overused stock images that have no association with the copy, but do represent 80 percent of the ethnicities on earth because someone told them to represent all ethnicities in their marketing materials. This belief that organizations have to visually represent all cultures in their target market is just not true. I have yet to see valid evidence and peer-reviewed research that shows using models representative of the target demographic substantially increases conversion. However, if you go and really examine the health care space and all of the marketing, you will see an abundance of these, “We are the world” stock photos. Do not market yourself like everyone else. Break the mold and make your brand get noticed.

It is about results
Do not go through the motions with your marketing efforts. Remember the end goal—results and a healthy marketing return on investment for your organization. A patient cannot just walk into a rehab clinic and demand electrical knee stimulation. Before any therapies are recommended, there is a solid medical strategy put in place by a trained professional. Organizations cannot assume that a print ad or a web banner will cure their marketing pains—they also need a strategy in place before any modalities are recommended. Just like with physical rehabilitation, the more attention and effort it receives, the healthier you will ultimately be.

Brandon Moser is the president and chief executive officer of HowlandMoser Advertising. He can be reached at HowlandMoser.com.

Make the Referral Process Easy

By Paul Martin, PT, MPT, CBI, M&AMI

If you are a company that makes regular contact with your referring physicians, consider a new strategy. As opposed to simply telling the physician why your services are so much better, or that you deliver higher quality over your competitors, why not lead with some questions? In our experience, physicians hear pretty much the same thing from every provider, and the majority of physicians do not see a considerable difference in quality from one provider to the next.

So why not have your marketing person or practice liaison lead with some great questions with the goal of finding out what could distinguish your practice from the rest of the providers in your market? While there are a number of questions to ask, how about, “What can we do to make the referral process easier for you and your office?” And then listen, respond, and deliver!


Paul Martin, PT, MPT, CBI, M&AMI, president of Martin Healthcare Advisors, is a nationally recognized expert on health care business development and succession planning. As a consultant, mentor, and speaker, Paul assists business owners with building value in their companies. He has authored The Ultimate Success Guide, numerous industry articles, and weekly Friday Morning Moments. He can be reached at pmartin@martinhealthcareadvisors.com.

Private Practices and Rehabilitation Agencies, CMS Requirements – Table Data

Private Practice
Rehabilitation Agency
Condition Y/N Comment Y/N Comment
Clinical Record Audits ? Not mandated, but auditing would be considered a proactive fraud and abuse prevention activity Yes Required in the Conditions of Participation (C of P)
Employee Safety & Emergency Education and Training Yes OSHA’s 29 CFR 1910 Yes C of P & OSHA
Infection Control/Bloodborne Pathogens (BBP) Policies/Procedures Yes OSHA/Bloodborne Pathogens Standard Yes C of P & OSHA
Hazard Protection Yes OSHA/Hazard Communication Standard Yes C of P & OSHA
Patient Safety Yes OSHA Yes C of P & OSHA
Environment & Equipment Preventive Maintenance Yes OSHA Yes C of P & OSHA
Personnel Policies ? Proactive for workers compensation (WC) and professional liability risk management and avoidance of “negligent hiring and retention” lawsuits Yes C of P
Patient Care Policies ? Professional ethics, practice acts, and professional liability risk management Yes C of P
Independent Agent/Staffing Yes Contractual terms required Yes C of P
Patient Record Management & Retention Yes Health Insurance Portability and Accountability Act (HIPAA) Yes C of P< & HIPAA
Payment-Billing Variances
Physician Fee Schedule Yes Yes
Billing on CMS 1500 Form Yes Physical Therapist (PT) and Practice’s National Provider Identifier (NPI) No
Billing on CMS UB-04 No Yes RA’s NPI
Billing Frequency Limitations No Daily or To Be Determined Yes Monthly
Coding & Reporting
Use of Correct Coding Initiative (CCI) Edit (59) Yes Yes
Use of Advance Beneficiary Notice (ABN) Yes Yes
Application of Therapy Cap (KX) Yes Yes
Reporting of Functional Limitations Yes Yes
Reporting of Physician Quality Reporting Scale (PQRS) Measures Yes No UB-04 limitation
Enrollment Variances
Enrollment is required for each therapist who treats Medicare patients Yes Claims have to be held until the therapist receives a Medicare Number (PTAN) No Therapists have no individual screening or enrollment requirements
State Agency Survey Required No Yes After the CMS enrollment application has been approved, the state agency or an accrediting organization must perform an in-depth physical plant and provider compliance survey based on the Conditions of Participation for the RA. There are fees for the survey as well as annual fees based on full-time equivalents (FTEs). There are multiple approval and review levels; time from beginning to end varies from 90-160 days
Therapists Application Forms: CMS 855i, 855r & sometimes the CMS 460 Yes No
Practice Application Forms: 855b, CMS 460, EFT 588 Yes Yes 855a & EFT 588
Enrollment/Revalidation Application Fees No Yes ~$500
Revalidation Applications: Practice & therapists Yes Both the practice and the therapists Yes Practice (RA) only
Certified Institutional Provider No Yes Only RA
Enrolled Supplier Yes Both the practice and the therapists Yes
Reassignment requirements (the PT has the option to grant the practice the right to receive payment for his/her services) Yes Both the practice and the therapists No The RA is automatically the billing entity; no reassignment is necessary
Therapist must have an NPI (national provider identification number) for billing purposes Yes Both the practice and the therapists No Only the RA is required to have an NPI and all charges are billed under the RA NPI
Practice/therapist participation (assignment from patient) Yes The therapist/practice may elect to accept patient assignment No RA must accept patient assignments
Site Survey related to Medicare enrollment/revalidation, practice site change, or the addition of a new therapist Yes This is a “proof” of existence survey; it is not an in-depth survey of charts, conditions, or compliance No RA is in the low-risk category but is subject to the State Agency Survey (see above)
Miscellaneous Variances
General supervision of a physical therapist assistant No Onsite supervision is required in the private practice setting Yes Unless state law is more stringent, Physical Therapy Assistants (PTAs) do not have to have onsite supervision
Two Person Duty Requirement No Yes Two individuals present during patient treatment
Facility Administrator No Private practices do not have to designate an administrator but some states do require that they designate a “charge therapist” Yes Yes RA is required to have a full-time administrator; this person needs to be qualified but does not have to be a physical therapist
Services can be provided in the patient’s home, Part B Skilled Nursing Facilities/Nursing Facilities, Assisted Living Facilities (SNF, NFs, ALFs) and Independent Living Facilities Yes Yes
Practice Site Change or Addition No The private practice must submit a practice site relocation, termination, or addition notification, via the 855b or 855i, within 30 days of the change but it is not typically subject to approval Yes When an existing RA intends to move its primary site or if it intends to move any of its approved extension locations to a new practice location or it desires to add a new practice location, it must first notify CMS within 90 days of the expected move or addition and seek approval from Medicare’s Regional Office before it can bill Medicare for covered services from the new address
Thirty-mile radius limitation for additional practice sites No Yes This only applies to RA if it relates to an extension site
Physical therapy or speech therapy (ST) must be provided at each practice site. Occupational Therapy (OT) cannot be the only service provided No Yes
Aquatic therapy provided in a community pool No The agreement with the community pool must indicate separate space but the pool does not need to be closed to the public Yes The pool must be closed to the public
Policies & Procedures Yes As a health care provider, the following are minimally required:
  • OSHA
  • ADA
Yes RA must have policies and procedures in place in order to comply with the Conditions of Participation as well as those mentioned for PTPP

PPS Grassroots Support Boosts Locum Tenens

By Alpha Lillstrom and Jerry Connolly
November 11, 2015

As we are coming up on Annual Conference and we look forward to seeing you all, we are pleased to report on a trio of legislative actions that represent various tenets of the Private Practice Section’s advocacy agenda.

Progress on Locum Tenens
As you know, this year Senators Charles Grassley (R-IA) and Robert Casey (D-PA) as well as Representatives Gus Bilirakis (R-FL) and Ben Ray Luján (D-NM) reintroduced the Prevent Interruptions to Therapy Act of 2015 (H.R.556/S.313) to authorize physical therapists to use the existing locum tenens provision of the Medicare statute so that the practice could bill and be reimbursed for treatment provided by a qualified provider when the practice owner is absent for a short time. In addition to easing the administrative burden on practice owners, including physical therapists in this provision would, more importantly, help to ensure that Medicare patients could continue their care without interruption. Simply put, this bill is a low-cost technical fix that would add physical therapists to the list of providers allowed to utilize locum tenens arrangements under Medicare (when all other conditions are met and within their same authorized scope of practice).

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