CMS Releases 2021 Final Rule for Services Reimbursed Under the MPFS

December 2, 2020
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Rick Gawenda
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On December 1, 2020, the Centers for Medicare and Medicaid Services (CMS) released the final rule for services paid under the Medicare Physician Fee Schedule (MPFS). This would include outpatient physical, occupational and speech therapy services provided in all outpatient therapy settings except for a critical access hospital.

Highlights of the final rule include, but are not limited to, the following:

  • 2021 Medicare Conversion Factor and 9% Payment Reduction
  • Accessing the 2021 Relative Value Units (RVU’s) for Each CPT Code
  • 2021 Annual Therapy Threshold Dollar Amount
  • Student Documentation in the Medical Record
  • Maintenance Therapy Provided by PTA’s and OTA’s
  • Communication-Based Technology Services
  • Remote Patient Monitoring CPT Codes
  • Telephone and Assessment Management Services CPT Codes
  • Revaluation of Physical and Occupational Therapy Evaluation and Re-evaluation CPT Codes
  • Revaluation of Speech Therapy Evaluation CPT Codes
  • Supervision Requirements of a PTA and OTA in the Private Practice Setting
  • G2061 – G2063 E-Visit HCPCS Level II Codes Changing to CPT Codes
  • Physical and Occupational Therapy Delivered via Telehealth

I will discuss the Merit-Based Incentive Program in a separate article. Here we go!

2021 Conversion Factor

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Accessing the 2021 Relative Value Units (RVU’s) for Each CPT Code

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2021 Annual Therapy Threshold Dollar Amount

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Student Documentation in the Medical Record

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Maintenance Therapy Provided by PTA’s and OTA’s

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Communication Technology-Based Services

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Remote Patient Monitoring CPT Codes

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Telephone and Assessment Management Services CPT Codes

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Revaluation of Physical and Occupational Therapy Evaluation and Re-evaluation CPT Codes

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Revaluation of Speech Therapy Evaluation CPT Codes

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Supervision Requirements of a PTA and OTA in the Private Practice Setting

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G2061 – G2063 E-Visit HCPCS Level II Codes

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Physical and Occupational Therapy Delivered via Telehealth

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How can I access the Final Rule?

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  1. Thanks Rick

    So right now therapists in a non-private practice can bill telehealth under the PHE. In this final rule, are they stating that is no longer the case starting Jan 1st, even thought the above codes remain through the end of the year in which PHE ends?

    1. Once the PHE is declared over, PTs, OTs and SLPs will not be able to be reimbursed by CMS for telehealth services.

  2. Thank you for the update.
    If CMS doesn’t have the authority to add PT’s as authorized practitioners who can independently bill Medicare for telehealth, then who does? It’s allowing it to be billed incident to?
    Thanks in advance.

  3. If CMS doesn’t have the authority to add PT’s as authorized practitioners, then who has this authority? The state?
    Curious about their language.
    Since physicians can bill for RPM are they able to bill for RPM if they employ a PT to do it for them?

    Thank you for your help.

  4. Can P.T.’s who bill on UB-04 do any kind of communication technology-based service?. I am not clear. Would appreciate the clarification. Thank you

  5. Can you provide more details about student documentation? Does this apply to Medicare B and all state Medicaid Program?

  6. Clarification question on student documentation. When CMS indicates “billing therapist” in “students can document in the medical record so long as it is reviewed and verified (signed and dated) by the billing therapist”…
    Does this change only cover private practice/1500 billing since therapists are direct billing providers? or does it also cover Hospital outpatient department therapists that bill facility/UB04?

  7. Can you clarify on 97530 and Telehealth billing? It appears looking at the link that it was a temporary addition for the PHE for the COVID-19 Pandemic.. so would assume it’s still billable until it is declared “over” but NOT until the end of that calendar year … but unclear since 97112 has a similar description but is included in your list of codes covered through the year end of the PHE being declared over.

  8. Hello Rick, This is Sandra in Heather’s office. I hope you are doing well. I just need clarification for HB therapy providers billng telehealth during PHE. Since Medicare has extended the PHE til1/21/21 therapy can still bill telehealth services for the following codes-correct? What about codes that are not listed?
    92521- 92524, 92507, 97161 – 97168, 97110, 97112, 97116, 97535, 97750, 97755, 97760, and 97761

  9. I want to be sure I am reading this correctly regarding billing incident to physician for Medicare patients when they have a physical/occupational therapy telehealth visit with a PT or OT in a private practice as if 1/1/21. We are allowed to bill incident to physician as long as the physician is immediately available to engage via audio/video technology, but they do not need to be directly involved in that patients visit, is that correct? Would the physician need to sign off on the therapy note for that day? Thanks!

  10. Do you know where in the 2021 Final Ruling of the MPFS that CMS clarified that students can document in the medical record, with review and signature of the billing therapist? Thanks for your assistance!