Medicare Therapy Fraud: PT, OT, and Speech Billing Abuse

Medicare pays separately or through bundled rates for physical, occupational, and speech therapy. Facilities where therapy revenue drives margins may push clinicians to document more minutes than delivered or treat patients who cannot benefit.

Examples of potential problems include recording treatment that did not occur, misrepresenting one-to-one versus group treatment, and billing care without supporting documentation. Whether a claim is improper depends on the setting and applicable coverage rules.

Historical skilled nursing cases sometimes involved RUG-IV therapy-minute thresholds. CMS replaced that SNF Part A classification with PDPM in October 2019. A historical ultra-high therapy category should not be presented as the current universal Medicare billing model.

Therapists asked to sign off on minutes they did not perform, or told that patient tolerance does not matter for billing targets, may be witnessing fraud — not just aggressive business practices.

Therapy fraud cases often combine medical necessity falsehoods with false claims for payment. Relators with documentation of corporate policies tying bonuses to therapy volume have helped DOJ recover millions.