Plan of Care and Progress Report Tracking

The basic policy and process for establishing, certifying, and reporting on Medicare Plans of Care.

Background Information

All citations are detailed in References list at the end of this topic.

Establishing Plan of Care

The Plan of Care may be established by the supervising physician or the treating therapist, but for practical purposes, the plan is nearly always established by the treating therapist.[1] The Plan of Care “shall be consistent with the related evaluation, which may be attached and is considered incorporated into the plan.”[2] The POC must include: Diagnosis, Long Term treatment goals, and type, amount, duration, and frequency of therapy services.[3] The evaluation may include a Plan of Care, but POC and evaluation are not synonymous from Medicare’s perspective.

Certifying Plan of Care

The POC must be certified by the supervising physician. The maximum certification period for a Plan of Care is 90 days.[4] The duration of the Plan of Care is approved by the physician. It is important to note that 90 days is the maximum. If the treatment plan is for less than 90 days, the duration of the Plan of Care should be adjusted.

Progress Reporting

In addition, there is a separate requirement for an interim Progress Report which provides justification for the medical necessity of treatment. Progress Reports are required at least every 10 visits.

Note: There is no requirement to send a Progress Report to the referrer and Progress Reports do not require certification. Plans of Care and Progress Reporting are not tracked when Medicare is secondary, only when it is primary.

Establishing a Plan of Care

In documentation for Medicare patients, an alert appears when reviewing the Case information to indicate that the Plan of Care has not yet been established:

After the Plan of Care has been established in the initial evaluation, double click on the Case Name to open the Client Editor and enter the duration of the Plan of Care:

Entering Plan of Care Information

Follow these steps to enter Plan of Care information for the patient in the Client Editor:

  1. In the Client Editor, click the Add POC button.

  2. The effective date will default to the date that the evaluation is being performed, but may be adjusted if necessary. The duration of the POC will normally default to 90 days:

    But you can adjust the duration date for Plans of Care less than 90 days:

Handling Plan of Care Expiration

Follow these steps to update Plan of Care information when the current Plan of Care expires:

  1. The Case Information will alert the therapist when the current Plan of Care expires and when a new Progress Report is required.

  2. To update the system after a Progress Report has been completed, click on Edit Plan of Care Dates, then the Add Prog Report button.


  1. The one notable exception is CORFs. There is some specific language stating that in CORFs the Plan of Care can only be established by a physician. Respiratory Therapists working in CORFs only have a 60 day certification period.
  2. Medicare Benefits Policy Manual, Section 220.1.2
  3. Medicare Benefits Policy Manual, Section 220.1.2, page 150
  4. Federal Register, p. 185:
  5. Medicare Benefits Policy Manual, Section 220.3, page 162.
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