Review Due Tracking
The due date is computed, and the formula is not the same on every row
One row per plan. Anchor type decides which formula runs, and the authority column is on the row so the date can be checked instead of trusted.
| Plan | Service line | Anchor date | Anchor type | Interval | Reviews recorded | Review due | Last review plus interval | Days late | Missed cycles | Signature | Change signed | Authority |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Service line | How often | Clock starts | Who reviews it |
|---|---|---|---|
| Outpatient therapy | At least every 90 days, or sooner if the certified plan ends first | First treatment under the plan, including the evaluation | The physician or practitioner who signs the recertification |
| Home health | At least every 60 days | Start of care, in fixed 60-day blocks | The responsible physician or allowed practitioner, with the agency |
| Hospice | At least every 15 calendar days | The last review, or the plan's start | The interdisciplinary group, with the attending physician if there is one |
These are federal minimums for Medicare. Medicaid programs, private payers and accreditors can require more, so record the strictest rule that applies to each plan.
Two Medicare behavioral health programs have their own clocks. Partial hospitalization is first recertified by the 18th day of services, then at least every 30 days3. Intensive outpatient is recertified at least every 60 days.
Confirm the plan has the required contents
The clinician writes the plan. Your job is to check that every required element is there before anyone signs it. For outpatient therapy the list is short: the plan prescribes the type, amount, frequency and duration of services and indicates the diagnosis and anticipated goals5.
Home health asks for far more. The plan of care must cover 15 specific items2, including all pertinent diagnoses, all medications and treatments, and measurable outcomes and goals. A hospice plan must include interventions to manage pain and symptoms, the scope and frequency of services and measurable outcomes1, among other items.
Check that every goal is measurable, ideally with a number and a target date, so the next review can say whether it was met. For behavioral health clinicians, the treatment plan writer drafts measurable goals from an intake assessment.
Then track every plan in one register, a row per plan, with these details:
- Service line and payer
- The date the clock starts, and the interval
- The rule behind that interval
- Last review date and next review due
- Who signed, and in what role
- Any change since the last signature, and whether it was signed
Set each review date from the right clock
The three clocks run differently. Hospice floats: every review starts a new 15-day count. Therapy runs to the end of the certified interval. Home health runs on a fixed grid: the comprehensive assessment must be updated in the last 5 days of every 60 days beginning with the start-of-care date6.
Compute every due date from the plan's own dates and clock type, and never type one in. Keep the rule on the same row, so anyone can check the arithmetic.
Outpatient therapy: evaluated on day 1, with the plan certified for 8 weeks. If treatment continues, recertify by day 56, not day 90.
Hospice: plan last reviewed on day 50. The next review is due by day 65.
Home health: start of care on day 1, so the 60-day reassessments fall on days 56 to 60, 116 to 120 and so on. One slips to day 63. The next is still due on days 116 to 120, but day 63 plus 60 says day 123.
- Certified interval. Recertification is due when the certified plan ends, even well short of 90 days.
- Floating clock. Hospice counts from the last review, so adding 15 days to it is correct.
- Fixed grid. Adding 60 days to a late home health reassessment pushes the deadline past the real one.
Count missed reviews as well as days late. A hospice plan 16 days late has missed two review dates, while a therapy plan 44 days late has missed one. Sorting by days late alone puts them in the wrong order.
Progress reports run on a clock of their own. For outpatient therapy, CMS requires one at least once every 10 treatment days4, and recertification dates don't change that schedule.
Treat signatures as a separate test
A plan reviewed on time can still fail on signatures. In outpatient therapy, any change to the plan must be made in writing, signed by a permitted clinician and incorporated in the plan immediately5. If a change sets new long-term goals, CMS's manual also requires the physician's or practitioner's certification within 30 days of the first treatment under the revised plan4.
Recertification has a narrower list of signers: the physician, nurse practitioner, clinical nurse specialist or physician assistant who reviews the plan3. A therapist can sign a change but not a recertification, so record the signer's role, not just a check mark.
Since January 2025, Medicare's certification rule has one exception, for the initial certification3. If a therapist writes the plan and a written order or referral is on file, no physician or practitioner signature is needed. The therapist must document that the plan was delivered to that physician or practitioner within 30 days of completing the initial evaluation.
In home health, the plan must be established, periodically reviewed and signed by a physician or allowed practitioner2. Whatever the service line, CMS's July 2025 fact sheet on complying with Medicare signature requirements7 says reviewers look for signed and dated documentation and may deny claims without it.
If a required signature is missing from a record other than an order, the record's author can supply it through an attestation. But an attestation can't backdate the plan of care, so collect each signature when it is due.
Audit the register every month
Set reminders as a share of each interval: around day 10 on a 15-day hospice clock and around day 70 on a 90-day certification. Then, once a month, list every late review and every unsigned change. Log them as separate findings, even when one plan has both, and note what caused each. The cause is what you fix.
Plan staffing around review events, not caseload. A hospice plan needs about 24 reviews a year and a 90-day therapy plan about four, so 10 hospice patients create six times the review work of 10 therapy patients.
Before you close a review
- The due date was computed from the right clock, not typed in
- The rule behind the interval is on the plan's row
- The review is dated and documented, even if nothing changed
- The signer is allowed to sign this kind of event
- Every change since the last signature is signed and in the plan
- Any late review or missing signature is logged as its own finding
When to get advice
This guide covers Medicare's federal minimums, not clinical content or coverage decisions. When a signature's validity or a payer's rule is unclear, ask your compliance officer or a healthcare attorney.
In behavioral health, the therapy progress note writer ties each session note to the plan's goals. If a claim is denied over a missing signature or a late recertification, the denial appeal template takes you from the denial to a filed appeal.
How to use this template
Fill in the Requirement Register first, then track each plan in the Review Due Tracking sheet and log problems in the Finding Register. Or open the template in River. It asks which service lines you run and which payers you bill, and records each one's interval, clock, rule and permitted signers. Then it works out every plan's next review date and lists late reviews and unsigned changes separately.
Download it or open it in River
Get the four Word documents and three CSV sheets free, or open the template in River to work with AI.
Fill in the requirement register
List each service line and payer with its review interval, where the clock starts, the rule behind it and who signs.
Work out every review date
Add each plan's start date and past reviews, then compute the next due date from its own clock, or let River do it.
Audit reviews and signatures monthly
List late reviews and unsigned changes as separate findings, close each one, and record what caused it.
What's in the template
Review Due Tracking
Illustrative figures for a fictional provider, Kestrel Health Services, read on 31 March 2026. Twelve plans, four in each service line. Dates are 2026 unless the anchor precedes it. The eighth column is what the wrong formula would have said.
| Plan | Service line | Anchor | Anchor type | Interval | Reviews recorded | Review due | Last review + interval | Days late | Missed cycles | Signature | Change signed | Finding |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| CP-101 | Outpatient rehab | 01-05 | Last cert, floating | 90 | 01-05 | 04-05 | Same formula | — | — | Yes | n/a | None |
| CP-102 | Outpatient rehab | 01-12 | Last cert, floating | 90 | 01-12 | 04-12 | Same formula | — | — | Yes | No, change 02-20 | Change unsigned |
| CP-103 | Outpatient rehab | 11-17 | Last cert, floating | 90 | 11-17 | 02-15 | Same formula | 44 | 1 | No | n/a | Review interval and signature missing |
| CP-104 | Outpatient rehab | 02-09 | Last cert, floating | 90 | 02-09 | 05-10 | Same formula | — | — | Yes | Yes, change 03-02 | None |
| CP-201 | Home health | 01-26 | Start of care, grid | 60 | 03-20 | 05-25 | 05-19 | — | — | Yes | n/a | None |
| CP-202 | Home health | 12-15 | Start of care, grid | 60 | 02-11; 03-25 | 06-12 | 05-24 | — | — | Yes | n/a | None |
| CP-203 | Home health | 02-02 | Start of care, grid | 60 | 03-15 | 06-01 | 05-14 | — | — | Yes | n/a | None |
| CP-204 | Home health | 11-03 | Start of care, grid | 60 | 12-28 | 03-02 | 02-26 | 29 | 1 | No | n/a | Review interval and signature missing |
| CP-301 | Hospice | 01-14 | Last review, floating | 15 | 03-20 | 04-04 | Same formula | — | — | Yes | n/a | None |
| CP-302 | Hospice | 02-02 | Last review, floating | 15 | 03-24 | 04-08 | Same formula | — | — | Yes | n/a | None |
| CP-303 | Hospice | 02-16 | Last review, floating | 15 | 03-18 | 04-02 | Same formula | — | — | Yes | n/a | None |
| CP-304 | Hospice | 01-27 | Last review, floating | 15 | 02-28 | 03-15 | Same formula | 16 | 2 | Yes | n/a | Review interval |
| Twelve plans | 89 | Two missing | One unsigned | Four with a finding |
Compare the seventh and eighth columns on the four home health rows. Every review on them fell inside its window, so last review plus 60 lands earlier than the grid date. CP-201 was reviewed six days before its first window closed: the grid puts the next date at 25 May, while last review plus 60 says 19 May, six days early. That direction only asks for work too soon. The dangerous direction is a late review, where last review plus 60 runs past the real deadline. CP-204 is simply overdue: its second window closed on 2 March with no review. CP-304 is the row a days-late sort gets wrong: 16 days on a 15-day interval is two missed review dates, against CP-103 at 44 days on a 90-day interval, which is one.
Requirement Register
One row per service line and payer, because a payer's contract can set a shorter interval than the federal one. All three federal intervals are minimums, which is what makes the contract column meaningful.
| Service line | Payer | Interval | Anchor type | Authority | Signature required from | Change needs its own signature | Contract shortens it | Interval used |
|---|---|---|---|---|---|---|---|---|
| Outpatient rehab | Medicare Part B | 90 | Last certification, floating | 42 CFR 424.24(c)(4)(i) and (iii) | Physician, NP, CNS or PA who reviews the plan | Yes | No | 90 |
| Outpatient rehab | Cascade Mutual | 90 | Last certification, floating | Plan medical policy 31-208 adopts the Medicare floor | Physician, NP, CNS or PA who reviews the plan | Yes | No | 90 |
| Outpatient rehab | Ridgeline Health | 90 | Last certification, floating | Provider agreement schedule C shortens the review to 60 | Treating physician | Yes | Yes | 60 |
| Home health | Medicare Part A | 60 | Start of care, fixed grid | 42 CFR 484.60(c)(1) | Physician or allowed practitioner responsible for the plan | Yes | No | 60 |
| Home health | State Medicaid | 60 | Start of care, fixed grid | State plan adopts the federal interval | Physician or allowed practitioner | Yes | No | 60 |
| Hospice | Medicare Part A | 15 | Last documented review, floating | 42 CFR 418.56(d) | Interdisciplinary group with the attending physician | Yes | No | 15 |
Row three is why this sheet is per payer rather than per service line. Outpatient rehabilitation is a 90-day interval everywhere except under one provider agreement that shortens it to 60, so two identical plans in the same service line have due dates a month apart and only the payer column explains it. The signer can differ by payer too: Medicare accepts the physician, nurse practitioner, clinical nurse specialist or physician assistant who reviews the plan, while Ridgeline's agreement asks for the treating physician, so "signed" is not one test. The authority column is the load-bearing one: a due date whose authority reads "our policy" cannot be defended, and everybody stops believing the register.
Finding Register
The same twelve plans arranged by service line, with exposure computed before findings are counted. Exposure is review events per year rather than plan count, which is the figure that decides how the work gets staffed.
| Service line | Plans | Interval | Review events per plan per year | Line exposure | Share of review events | Share of plans | Findings | Interval only | Signature only | Both |
|---|---|---|---|---|---|---|---|---|---|---|
| Hospice | 4 | 15 | 24.33 | 97.32 | 70.6% | 33.3% | 1 | 1 | — | — |
| Home health | 4 | 60 | 6.08 | 24.32 | 17.6% | 33.3% | 1 | — | — | 1 |
| Outpatient rehab | 4 | 90 | 4.06 | 16.24 | 11.8% | 33.3% | 2 | — | 1 | 1 |
| Total | 12 | 137.88 | 100% | 100% | 4 | 1 | 1 | 2 | ||
| Findings per hundred review events | 2.9 |
Four plans in each line and hospice carries 70.6% of the review work, because 365 over 15 is 24.33 events a plan a year against 4.06 for rehab, a ratio of exactly 6.0. That is the sentence to take away: review work is not proportional to caseload and staffing it as though it were is how a fifteen-day interval quietly becomes a sixteen-day one. The finding columns then separate what an audit finds from what a practice never finds on its own. The two both-columns entries are the obvious cases, a late review on an unsigned plan. The signature-only entry is CP-102, which is current on schedule and correctly signed for its certification, and has a change from 20 February that nobody signed. Nothing about that plan looks wrong until you ask the second question.
- Plan Format by Service TypePlan layouts for outpatient therapy, home health and hospice, with clinical fields left blank for the clinician.
- How the Review Date Is DerivedEach line's interval, where its clock starts and the rule behind it, plus formulas for missed reviews and workload.
- Review and Update ProcedureSix steps, from computing due dates and timing reminders to recording unchanged reviews and closing findings.
- Signature Requirements NoteHow signing a periodic review differs from signing a change, and the four columns that record both.
- Requirement Register sheetOne row per service line and payer: interval, clock type, the rule behind it and who must sign.
- Review Due Tracking sheetEach plan's next review date, days late, missed reviews and signature status, with 12 example plans.
- Finding Register sheetLate reviews and signature gaps counted separately for each service line, beside its yearly review workload.
Common questions
What are the documentation requirements for a treatment plan?
Under Medicare, care must follow a written plan that includes everything its service line requires, is reviewed or recertified on schedule, and carries every required signature. For outpatient therapy, that means the diagnosis, goals, and the type, amount, frequency and duration of services. Home health and hospice plans need more, and each line sets its own review interval and signers.
How often does a plan of care need to be reviewed?
Medicare sets the minimum by service line: every 15 calendar days for hospice, and every 60 days from the start of care for home health. Outpatient therapy plans are recertified at least every 90 days, or sooner when the certified plan is shorter. A payer contract or accreditor can set an earlier deadline, so track the strictest rule for each plan.
Does a change to the plan need its own signature?
Yes, in outpatient therapy and home health. A therapy change must be written, signed by a permitted clinician and added to the plan right away, not held for the next recertification. Medicare's home health rules require every change to be signed and dated by a physician or allowed practitioner. So a plan can be on schedule and still fail on one unsigned change.
What is the difference between a care plan and a treatment plan?
In Medicare documentation, mostly the name. CMS's therapy manual notes the plan is "also known as a plan of care or plan of treatment." The home health and hospice rules call it a plan of care. What changes the requirements is the service line: it decides what the plan contains, how often it is reviewed and who signs.
Do I need a signature if a review changes nothing?
Yes, for therapy recertifications and home health reviews. A therapy recertification must be signed by the physician or practitioner who reviews the plan, even when nothing changes. Each home health review must carry the reviewer's signature and the date. In hospice, the interdisciplinary group must document each review. Record every completed review, or the plan will look overdue.
Is this treatment plan documentation template free?
Yes. Download the four Word documents and three CSV sheets with no signup. The sheets come filled with an illustrative example of 12 plans across outpatient therapy, home health and hospice, so you can see how the dates work before clearing them. Edit with AI opens the same template in River.
What does Edit with AI do?
It opens the template in a free River workspace. River builds the requirement register from your service lines and payers, computes each plan's next review date, and reports late reviews and unsigned changes as separate findings. It won't draft, edit or judge the clinical content of a plan; that stays with the clinician.
Sources
eCFR. “42 CFR 418.56 — Condition of participation: Interdisciplinary group, care planning, and coordination of services.” ecfr.gov (opens in a new tab)
eCFR. “42 CFR 484.60 — Condition of participation: Care planning, coordination of services, and quality of care.” ecfr.gov (opens in a new tab)
eCFR. “42 CFR 424.24 — Requirements for medical and other health services furnished by providers under Medicare Part B.” ecfr.gov (opens in a new tab)
CMS. “Medicare Benefit Policy Manual, Chapter 15 – Covered Medical and Other Health Services.” cms.gov (opens in a new tab)
eCFR. “42 CFR 410.61 — Plan of treatment requirements for outpatient rehabilitation services.” ecfr.gov (opens in a new tab)
eCFR. “42 CFR 484.55 — Condition of participation: Comprehensive assessment of patients.” ecfr.gov (opens in a new tab)
CMS. “Complying with Medicare Signature Requirements.” cms.gov (opens in a new tab)
Written by
Chandler Supple
Co-founder & CEO, River
Chandler has spent the last six years working in AI, building tools for millions of users and Fortune 100 companies. In 2025, he co-founded River to build a new kind of operating system for AI agents.