CMS Releases CY 2022 Proposed Rule for Outpatient Therapy
On July 13, 2021, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2022 proposed rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS). This rule does apply to outpatient physical, occupational and speech therapy services provided in all outpatient therapy settings except a critical access hospitals. This proposed rule only applies to traditional Medicare and not Medicare Advantage plans.
Highlights of the final rule include, but are not limited to, the following:
- CO and CQ Assistant Modifiers Payment Reduction Calculation
- Adding Therapy Services to the List of Medicare Telehealth Services
- Therapy Codes Removed From Telehealth List Once PHE Ends
- Category 3 Telehealth Codes (Includes PT, OT and SLP)
- Remote Therapeutic Monitoring
- Supervision Requirements of an Assistant in the Private Practice Setting
- CO and CQ Assistant Modifier Application Examples
- CY 2022 Conversion Factor
- Proposed Relative Value Units for CPT Codes
- Proposed Geographic Price Cost Index
- MIPS 2022 Performance Period Proposed Changes
CO and CQ Assistant Modifiers Payment Reduction Calculation
Adding Therapy Services to the List of Medicare Telehealth Services
Therapy Codes Removed From Telehealth List Once PHE Ends
Category 3 Telehealth Codes (Includes PT, OT and SLP)
Remote Therapeutic Monitoring
Supervision Requirements of an Assistant in the Private Practice Setting
CO and CQ Assistant Modifier Application Examples
CY 2022 Conversion Factor (CF)
Proposed Relative Value Units for CPT Codes
Proposed Geographic Price Cost Index
MIPS 2022 Performance Period Proposed Changes
CMS will accept comments on the proposed rule until 5:00pm ET on September 13, 2021. I hope you will submit your comments to CMS as your voice does matter. Thank you for being a Gold Member!
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All material posted on our website is the intellectual property of Gawenda Seminars & Consulting, Inc. and can’t be used, reproduced, or posted as your own material without the prior written approval of Gawenda Seminars & Consulting, Inc.
This article is not intended to and does not serve as legal advice or as consultative services, but is for general information purposes only.
Based on your summary, we will remain unable to bill Medicare for telehealth services after the PHE for COVID 19? I understand this is not final but it sounds like it will likely not be approved.
You had mentioned earlier in the year that Congress had not declared PT’s as telehealth practitioners, this sounds like it hasn’t changed either?
Hi Rick. Do the new Medicare supervision requirements for PTA’s in the private practice setting also apply to medicare advantage plans?
This proposed rule only applies to traditional Medicare.
Do you have an article talking about the PTA supervision requirements for federal payors like workers comp in the private practice setting?
No since each payer would be payer specific.
Regarding the CO and CQ payment reduction…
After an intensive advocacy effort by the APTA , the APTA announced a change in the provisions allowing seperate reporting on two different claim lines for services provided by both a PT and PTA. This seems cear.
However, APTA also announced “when the PT is involved for the entire duration of the service and the PTA provides skilled therapy alongsice the PT, the CQ modifier isn’t required.”
Could you provide an example of that would meet this standard?
PT is gait training a patient and needs a second person. That second person is the PTA. Since the PT is involved, those minutes would count as if the PT did the gait training by him/herself.
If we (PT/OT/ST) are able to prevent surgical interventions and other unnecessary medical costs, why does Medicare continue to cut? Any suggestions on proactive measures myself and colleagues could take to increase payments?
Once APTA releases their template letter to submit comments on the proposed rule to CMS, I’ll post that on my website. In addition, look for template letters to send to your Senator and House of Representative.
When do we anticipate hearing from CMS PTA Supervision?
CMS is still accepting comments on the proposed rule until September 13, 2021 at 5:00pm ET. The final rule is due out on or around November 1, 2021.
Does the PTA Modifier apply to supervised (non-timed) modalities (such as unattended electrical stimulation (97014/G0283) or mechanical traction (97012)? Thank you!