CMS Releases CY 2021 Proposed Rule for Services Paid Under the MPFS
The Centers for Medicare and Medicaid Services (CMS) has released the calendar year (CY) 2021 Proposed Rule for services paid under the Medicare Physician Fee Schedule (MPFS). This would include outpatient physical, occupational and speech therapy services provided in all settings (private practice (both therapist-owned and physician-owned, skilled nursing facilities doing Part B, comprehensive outpatient rehabilitation facilities, rehabilitation agencies, home health agencies providing Part B therapy services in the home and hospital outpatient therapy departments). This proposed rule would not apply to outpatient therapy services provided by critical access hospitals (CAHs) since CAHs are not reimbursed under the MPFS.
Highlights of the proposed rule as they pertain to outpatient therapy services include:
- CY 2021 Conversion Factor (used to determine payment of CPT codes)
- Brief online assessment and management services
- Remote evaluation of patient-submitted video or images and virtual check-ins
- Telephone assessment and management services
- Remote physiologic monitoring services
- Direct supervision by interactive telecommunications technology
- Revaluation of therapy evaluations and reevaluations for PT and OT
- Revaluation of speech therapy evaluation CPT codes
- Therapy assistants furnishing maintenance therapy
- Therapy student documentation in the medical record
- Physical, Occupational and Speech Therapy 2021 payment cuts
CY 2021 Conversion Factor
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Brief Online Assessment and Management Services
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Remote Evaluation of Patient-submitted Video or Images and Virtual Check-ins
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Telephone Assessment and Management Services
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Remote Physiologic Monitoring Services
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Direct Supervision by Interactive Telecommunications Technology
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Revaluation of Therapy Evaluations and Reevaluation CPT Codes for PT and OT
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Revaluation of Speech Therapy Evaluation CPT Codes
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Therapy Assistants Furnishing Maintenance Therapy
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Adding Therapy to the Medicare Telehealth Services List
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Physical, Occupational and Speech Therapy 2021 Payment Cuts
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Access Proposed Rule
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I hope you found this article informative. Watch for a separate article on the proposed 2021 Merit-Based Incentive Program (MIPS). Thank you for being a Gold Member!
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Is the rule allowing for the virtual presence of the supervising provider via telecommunications allowed now at this time or does this rule have to be finalized?
It’s allowed now due to the PHE due to COVID-19.
Does the PTA/OTA doing maintenance therapy apply in a clinic also or just Home Health and Skilled Nursing Facilities?
This proposed rule deals with outpatient therapy services in all settings.
Is this proposed cut a done deal?
It’s proposed!
The title of your email leading up to this discussion says a 20% cut for Outpatient Physical Therapy. APTA is publishing 9%. Which is correct?
The article has been updated as the 10.6% conversion factor reduction is already taken into account with the proposed 9% payment cut for outpatient PT, OT and SLP services.
Why would adding codes cause payment to go down for OT/SP?
CMS increased payment for may of the E/M codes used by physicians. Due to budget neutrality requirements, when monies are spent in one area, they need to be offset in other areas. That is the simple explanation.
Is part of the 9% reduction a result of reducing reimbursement for services rendered by a PTA/OTA by 15%?
No. The PTA and OTA payment reductions do not start until January 1, 2022.
Where did 20% come from. Did they add on to the 9%? or is that referring to PTA cuts
The article has been updated as the 10.6% conversion factor reduction is already taken into account with the proposed 9% payment cut for outpatient PT, OT and SLP services.
What do you know about the people reading the submissions through the portal at https://beta.regulations.gov/document/CMS-2020-0088-0001/
Are they required to read every submission?
What carries more weight? Emotional appeals or analytical arguments?
They read the comments we send in. This is from APTA and will help you.
Clinician and patient template letters to CMS are available via the APTA Regulatory Action Center: https://www.apta.org/advocacy/take-action/regulatory under the header CMS Proposed 2021 Physician Fee Schedule and Quality Payment Program Rule.
What is the proposed supervision requirement for PTA’s in the out patient setting?
Direct Supervision or General Supervision?
There is no proposed permanent changes to the supervision of a PTA or an OTA in the private practice setting.
Just want to clarify/confirm something I read in an article. Is it correct to bill treatment done in a SNF by a therapist in a different room or section of the same building same as in in person visit? (Or should this be billed as telehealth?)
Would be as an in-person visit.
Thank you so much!
I really appreciate you!