CMS Releases CY 2024 Medicare Physician Fee Schedule Final Rule
On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) final rule. This final rule does have regulatory and reimbursement implications for outpatient physical, occupational, and speech therapy provided in all outpatient therapy settings in calendar year 2024. In this article, I will inform you of what CMS finalized on the following topics:
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I’ve read the info on the final rule on PTA/COTA supervision in private practice but I still am not sure if it’s saying PTA/COTA‘s can continue to treat under general supervision of a PT/OT with direct telecommunication.
Please go back and read and I added additional language to assist you and others.
Thank you again for the great content!
You are welcome! Thank you for being a member!
Did CMS finalize anything regarding the need for an EHR in order to report MIPS? Or is an EMR allowed to report in 2024?
Please read the topic Promoting Interoperability Performance Category in this article.
Question regarding PTA and COTA supervision.
What level of supervision is required for OP services provided in a Hospital based OP clinic? Also related, can a Hospital based OP Therapy clinic send a PT or PTA to a patients home for Treatment under MC part B? This is not related to any Home Health services.
Please read this article for supervision requirements in a hospital setting:
https://gawendaseminars.com/supervision-requirements-of-an-assistant-in-2023/
You could send a therapist into a patient’s home and do OP therapy in the home.
Questions on new CPT codes for care giver training.
1- Verifying these do not contribute to the 8 min rule (asking based on the subsequent being in 15 min increment)
2- Can these be used if training while the patient is present? Or ONLY when the patient is not present?
3- Beyond what is in the rule, any other guidance for the consent documentation needs?
Please read this article: https://gawendaseminars.com/new-caregiver-training-services-cpt-codes/
Hi Rick,
Two questions related to Telehealth with Medicare in outpatient private practice
1. When the treating Provider is offsite (remote) and the patient is receiving their telehealth care within the clinic vs the patient’s home, is there any guidance/clarity on POS based on provider location?
2. If Medicare requires physical therapists home address – where would that information be reported on the PECOS application if therapist has reassigned payments to our group? The group enrollment does not list a therapists home address as a location. If it needs to be reported on the Individual PECOS application, would it be reported as a practice address in section 4 even though that is not the address that will appear on the billing since payments are reassigned?
1. You would use the POS for where the in-person visit would have occurred
2. There is now a revised PECOS application that expands practice location types to include telehealth.
The new caregiver codes… it states without the patient present. Does this mean that it can’t be charged if the patient is present?
That is what it means.
Hi Rick, Thanks as always for your assistance clarifying CMS info.
Does a Medicare member who prefers telehealth ever have to be seen in person periodically, or can they be seen via telehealth exclusively from eval to DC?
Under Medicare rules and regulations, yes. Check with state if they have any different requirements.
Thank you for putting this together Rick!
For the new caregiver training codes, specifically 97550: Is there a minimum amount of time required to bill the services? Is it 8 minutes, 16 minutes, 23 minutes? I appreciate any insights you can provide!
Please read this article to obtain your answer:
https://gawendaseminars.com/new-caregiver-training-services-cpt-codes/
Any indication that the new caregiver training codes will have MUE’s?
There are no MUEs for the new codes beginning January 1, 2024.