What Is a Plan of Care? Definition for Cash-Based Clinics
A plan of care is the written treatment plan set after an evaluation, stating the diagnosis, goals, and the type, amount, frequency and duration of care; in a cash clinic, it is what patients buy.
A plan of care is the written recommendation for how many visits, of what kind, over how long, to reach a stated goal. In a cash clinic it doubles as the product. Rehab Lab, a two-location cash PT client in Wisconsin, sells packages from $5,000 for 12 visits, and its shockwave program carries a $2,850 plan of care. That number, not the first-visit price, is what each new patient is worth to the clinic.
What has to be in a plan of care?
A plan of care has to state the diagnosis, the goals, and the type, amount, frequency and duration of treatment. That wording comes from Medicare's outpatient rehab rule, 42 CFR 410.61, which says the plan "prescribes the type, amount, frequency, and duration" of services and "indicates the diagnosis and anticipated goals" (eCFR). Even if you never bill Medicare, those five pieces make a good template, because they are also what a patient needs to say yes: what is wrong, what we are aiming for, and what it takes.
| Element | Example for a cash PT shoulder case |
|---|---|
| Diagnosis | Rotator cuff tendinopathy |
| Goal | Overhead press pain-free in 8 weeks |
| Type | Manual therapy, loading program |
| Frequency | 2 visits a week, then 1 |
| Duration | 12 visits over 8 weeks |
Does Medicare require a signed plan of care?
Yes. For Medicare patients, the plan must be certified by a physician or qualified practitioner, even in direct access states. Under 42 CFR 424.24, if a physical therapist establishes the plan, a physician, nurse practitioner, clinical nurse specialist or physician assistant who knows the case generally must sign the certification, and "recertification is required at least every 90 days" (eCFR). The one exception, in paragraph (c)(5): if a written order or referral from the physician or practitioner is in the record and the therapist documents sending the plan to them within 30 days of the initial evaluation, the initial certification does not need their signature. See Medicare and cash-based physical therapy for how this plays with a cash model.
Why does the plan of care matter for marketing math?
The plan of care sets the value of a new patient, and that value decides what you can afford to spend to get one. If your plan is worth $1,800 and only 60% of evaluations accept it, an evaluation is worth about $1,080 (our arithmetic: $1,800 x 60%). Price packages to match the plans you actually recommend; the package pricing calculator and cash-based PT pricing guide help.
This is general information, not legal or billing advice; check your state board and a healthcare attorney before you change how you bill.
Questions owners ask
Who writes the plan of care?
The treating clinician writes it after the evaluation. Under Medicare rules, 42 CFR 410.61 lets a physician, the treating physical therapist, or a nurse practitioner, clinical nurse specialist or physician assistant establish it before treatment begins.
How often does a Medicare plan of care need recertifying?
At least every 90 days, signed in the medical record by the physician or qualified practitioner reviewing it, per 42 CFR 424.24.
Is a package the same as a plan of care?
Not quite. The plan of care is the clinical recommendation; the package is how a cash clinic prices and sells it. Good clinics build packages that match the plans they actually recommend.