Medicare Payments for Outpatient Therapy in 2025

November 4, 2024
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Rick Gawenda
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On November 1, 2024, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2025 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 this article, I will provide my members with the estimated payment amounts for calendar year 2025 for the more common CPT codes billed in outpatient physical, occupational and speech therapy compared to the 2024 payment rate for each CPT code. For my examples, I used the national payment averages for each CPT code. Based on the location of your clinic/organization, your payment may be higher or lower than the national average.

Keep in mind that the estimated payments will change if Congress passess legislation increasing the conversion factor for CY 2025. Also, remember that some state Medicaid programs, workers compensation carriers, and commercial insurance carriers base their reimbursement on a percentage of the Medicare allowed amount for each CPT code. This means if Medicare reimbursement decreases in 2025, this could impact Medicaid, workers compensation, and commercial insurance carriers that base their payment on a percentage of the Medicare allowed amount.

Warning: A beverage (alcoholic) may ease the pain when reading the article and aspirin and/or cold pack for your head may be required when finished reading (or another beverage).

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This article is not intended to and does not serve as legal advice or as consultative services, but is for general information purposes only.

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  1. For the change in signed plan of care requirements, is this change is only for plan of cares that match the referral frequency/duration and diagnosis or is it a blanket guideline for any plan of care that has a referral? A few specific possibilities that cand and do arise include the following:

    A therapist alters the POC from what was on the initial referral? (i.e. referral says 2x/week for 6 weeks, but the therapist POC is 1x/week for 12 weeks)

    A therapist adds a body part that isn’t on the referral? (i.e. referral is for knee pain and the therapist wants to also evaluate and treat the back)

    If either of the above happen, does a signature become required?

    1. CMS only states in the final rule that the discipline of therapy must be on the order/referral and it must be signed and dated by a physician or NPP. The frequency and duration will be determined by the therapist in their initial evaluation and plan of care that is sent to the physician. If the physician does not disagree and send a change back to you, their “silence” means they agree with your plan of care.