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CMS Issues Final Rule for Services Paid Under the MPFS & MIPS for PT and OT

by • November 1, 2018 • 16 Comments

On November 1, 2018, the Centers for Medicare and Medicaid Services (CMS) issued the 2019 final rule for services paid under the Medicare Physician Fee Schedule (outpatient PT, OT and SLP services) as well as the Merit-Based Incentive Payment System (MIPS) for physical therapists, occupational therapists and speech-language pathologists in private practice.

Highlights of the Final Rule include:

  • 2019 Conversion Factor
  • 2019 Therapy Threshold Dollar Amount
  • 2019 Targeted Medical Review Dollar Amount
  • Functional Limitation Reporting for 2019
  • New Modifiers to Distinguish Services Provided by a PTA or OTA
  • “In Whole or In Part” Defined of a PTA or OTA Service
  • 2019 MIPS for Physical Therapists, Occupational Therapists and Speech-Language Pathologists

Lets Begin!

2019 Conversion Factor

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16 thoughts on “CMS Issues Final Rule for Services Paid Under the MPFS & MIPS for PT and OT”

  1. Gerriann Samowski says:

    Thank you for sharing this information and being a great resource.

    1. Rick Gawenda says:

      Thank you for the kind words and for being a Gold Member to our website.

  2. Mike Nichting says:

    Rick, regarding the Functional Limitation Reporting coming to the end – is that the functional G codes that we submit on eval and every 10th visit?

    1. Rick Gawenda says:


  3. Jacob Gleason says:

    What is the threshold for MIPS? Is it an annular dollar amount, visit limit or # of lives?

    1. Rick Gawenda says:

      None of what you mentioned. I will be doing a webinar on MIPS on December 18th from 1:00pm – 3:30pm where I will answer many questions about MIPS. I will also be writing several article on MIPS in the coming weeks.

  4. Amy Burba says:

    Rick, Will hospital based outpatient therapists be required to participate in MIPS in 2019?

    1. Rick Gawenda says:

      MIPS applies to practices that submit claims on a 1500-claim form.

  5. Lynn Stier says:

    Can Clarify the Functional limitations reporting for 2019?

    so we do NOT need to report for require med B and only supplemental medical insurance?

    1. Rick Gawenda says:

      FLR is ending for traditional Medicare. You will have to check with Medicare Advantage plans and other insurance carriers to determine if they will continue with FLR.

  6. Tom Bednar says:

    For practices over 15 eligible providers ( PT, OT and ST) will they be able to report the MIPS data via claims?

    1. Rick Gawenda says:


  7. Suzanne Chase says:

    Hi Rick,
    We are a private practice that does not participate with Medicare or Medicaid, so will we be required to participate in MIPS, or not? Thank you

    1. Rick Gawenda says:

      MIPS applies only to traditional Medicare Part B. If you do not participate with Medicare, then you can’t participate in MIPS.

  8. Kim Palma says:

    Hi Rick, thanks for the great info as always. can you tell me if they have finalized the rule to remove the Functioning reporting as of 1/1/19, or are we still waiting for confirmation. thanks Kim

    1. Rick Gawenda says:

      That answer is in this article.

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