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When Progress Reports Are Due

· 6 min read
Ben Gorman
Ben Gorman
RehabAlpha founder & developer

This guide explains how RehabAlpha determines when a Progress Report is due. Our logic is designed to align with CMS (Medicare) and state requirements, while allowing facilities to configure stricter internal or payor-specific rules where applicable.

important

This article is informational only. Final responsibility for compliance always rests with the provider and facility. Regulations may change.

What Determines When a Progress Report Is Due?​

Several factors influence how RehabAlpha calculates Progress Report due dates:

  • Payor

    • Medicare Part A
    • Medicare Part B
    • Managed Medicare
    • Commercial Insurance
    • Medicaid (state-specific)

  • Facility / Setting

    • Skilled Nursing Facility (SNF)
    • Inpatient Rehabilitation Facility (IRF)
    • Outpatient / Private Practice
    • Home Health

  • Discipline

    • Physical Therapy
    • Occupational Therapy
    • Speech-Language Pathology

RehabAlpha evaluates these inputs to determine:

  • When a Progress Report is due
  • Which encounters count toward that requirement

Do MACs or LCDs affect timing?​

No.
Local Coverage Determinations (LCDs) and Medicare Administrative Contractors (MACs) may affect what must be documented, but they do not change when a Progress Report is due. Timing is set nationally by CMS.

Skilled Nursing Facilities (SNF)​

Medicare Progress Report Timing (CMS Federal Rule)​

CMS defines a Progress Report Period as:

At least once every 10 treatment days or once every 30 calendar days, whichever occurs first.

This requirement applies nationally and does not vary by state.

Reference:
Medicare Benefit Policy Manual, Chapter 15

When does the clock start?​

The reporting period begins on the first day of the episode of treatment, regardless of whether that day includes:

  • An evaluation
  • A re-evaluation
  • A treatment visit

In RehabAlpha, this is typically the evaluation start date for a therapy case.

When does the first reporting period end?​

The first reporting period ends when any one of the following occurs:

  1. A Progress Report is completed
  2. 10 treatment days have occurred
  3. 30 calendar days have elapsed

Whichever comes first.

Examples​

Assume a PT evaluation occurs on January 1, 2025.

Scenario 1: No follow-up visits​

  • No treatments occur after the evaluation
  • Calendar-day clock continues
  • Reporting period ends at 11:5PM on January 30
  • Progress report is due within 7 days of the end of the period (by 11:59PM on February 6)

Scenario 2: Low-frequency treatment (2x/week)​

  • Fewer than 10 treatment days occur
  • 30 calendar days occurs first
  • Reporting period ends at 11:5PM on January 30
  • Progress report is due within 7 days of the end of the period (by 11:59PM on February 6)

Scenario 3: High-frequency treatment (5x/week)​

  • 10th treatment day occurs on Jan 12 (before 30 calendar days)
  • Reporting period ends at 11:5PM on January 12
  • Progress report is due within 7 days of the end of the period (by 11:59PM on January 19)

Scenario 4: Early Progress Report​

  • A Progress Report is completed on January 7 (before 10 tx days and 30 calendar days)
  • The reporting period ends on January 7
  • The next reporting period does not begin until the next treatment day

Subsequent Reporting Periods​

After a reporting period ends:

  • The next reporting period begins on the next treatment day
  • There may be gaps between reporting periods if no treatment occurs
  • Calendar days during gaps do not count toward a reporting period until treatment resumes

Key Clarifications​

What is a “treatment day”?​

A treatment day is any calendar day in which billable skilled therapy is provided.

  • RehabAlpha only counts days on which a treatment occurs
  • RehabAlpha does not count evaluations and re-certifications unless a treatment also occurs on the same day
  • RehabAlpha does not count missed or canceled treatments, even if scheduled

Multiple visits in one day​

  • Multiple treatments on the same calendar day count as one treatment day

Patient absences​

  • Absences do not pause the 30-day clock
  • A Progress Report may still be due even if the patient is absent near the end of the period

Time zone​

  • All timing is calculated using the facility’s local time zone

Medicare Part A vs Part B Differences​

Medicare Part A (Bundled)​

  • Treatment days are counted once per calendar day if any skilled therapy occurs on that date
  • Discipline does not matter
  • When the reporting period ends, each discipline involved must complete a Progress Report

Medicare Part B (Fee-for-Service)​

  • Treatment days are counted separately for each discipline
  • PT, OT, and SLP each have independent reporting periods

State Rules and Facility Policies​

CMS does not allow states to override Medicare Progress Report timing.

However:

  • Some state practice acts
  • Some facility or corporate compliance policies
  • Some non-Medicare payors

may require earlier or more frequent progress documentation.

RehabAlpha allows these stricter rules to be configured, but they are not Medicare requirements.

State requirments​

Some states have progress report timing rules that are stricter than CMS...

todo: check if this is correct. Find a source

Physical Therapy​

StateMedicare Pt A & Managed Care Pt AAll other payor types
NV7th tx day or 14th calendar day7th tx day or 21th calendar day
SC8th tx day or 14th calendar day8th tx day or 30th calendar day
VT5th tx day or 14th calendar day5th tx day or 30th calendar day
All others4th tx day or 14th calendar day4th tx day or 30th calendar day

Occupational Therapy​

StateMedicare Pt A & Managed Care Pt AAll other payor types
NV10th tx day or 14th calendar day10th tx day or 30th calendar day
SC7th tx day or 14th calendar day7th tx day or 30th calendar day
VT10th tx day or 14th calendar day10th tx day or 30th calendar day
All others10th tx day or 14th calendar day10th tx day or 30th calendar day

Speech-Language Pathology​

StateMedicare Pt A & Managed Care Pt AAll other payor types
NV10th tx day or 14th calendar day10th tx day or 30th calendar day
SC10th tx day or 14th calendar day10th tx day or 30th calendar day
VT10th tx day or 14th calendar day10th tx day or 30th calendar day
All others10th tx day or 14th calendar day10th tx day or 30th calendar day

Common Edge Cases RehabAlpha Handles​

  • Mid-episode payor changes (e.g., Part A → Part B)
  • Multiple disciplines treating the same patient
  • Missed or skipped treatment days
  • Early Progress Reports
  • Documentation completed without same-day patient contact
  • Facility-specific stricter documentation policies

How does RehabAlpha handle upcoming and overdue progress reports?​

todo: discuss notices

Questions or Corrections?​

If you have questions, believe a rule is being applied incorrectly, or notice a regulatory change:

📧 support@rehabalpha.com

We actively update our logic to reflect evolving guidance and appreciate feedback from clinicians and administrators.