Proposed Rule for Rehab Coming Soon to Your Practice!

By Daniel Morrill, PT, DPT / Co-Founder - CEO & President

Changes are coming...

Last night, I began to read the 1,704 pages of the CY 2020 Revisions to the Payment Policies under the Physician Fee Schedule, otherwise known as the Proposed Medicare Changes for Part B for the upcoming year (2020).

The first 240-ish pages were relatively benign for the rehab industry. However, once you find your way onto page 249 (Section M), we are once again reminded that simplifying rehab documentation and billing requirements and guidelines often means the rules grow more specific and complex.

KX use will remain the same to attest for medically necessary services, which means making sure your documentation supports continuing care once you reach the Medical Review Trigger.   Speech and Physical Therapy will still retain its Medical Review Trigger (MR Process) at $3,000 (this total is, again, combined), while OT also remains the same at $3,000.

Now for the fun: PTA and OTA reimbursement reduction. Truth be told, this was the cost of replacing the arbitrary cap on rehab services. Someone had to pay the price. PTA and OTA will be reimbursed at 85% for services rendered (these reductions will not start until 2022). If PTAs and OTAs treat whole or in part, a CQ (Outpatient PTA) or CO (Outpatient OTA) Modifier will be required on the applicable service line.

The “whole” part is not too difficult to figure, but the “in part” is going to be interesting. CMS has come up with a “simple” method for determining how to determine the usage of CQ/CO Modifiers when only part of the treatment is performed by the PTA or OTA. The proposed rule contains language that a de minimus (which means “of minimum importance”) standard be used; which states if more than 10% of the service is furnished by the PTA or OTA, then the modifiers will need to be applied to that service. The bottom line is that if a PTA or OTA performs a service to a patient and it is more than 10% of the time (when combined with a PT/OT), the modifiers must be used, and the 15% reduction in rates is applied (again, the reductions will not start until 2022).

CMS did include two methods for calculations which Hands on Technology (TheraOffice) will present at a future webinar. At Hands on Technology, we have started the process of evaluating changes that will need to be made to support this new rule. MIPS changes seem minor in the proposed rule, so we are still filtering through the regulations. Stay tuned for more!

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