Next Event: NCCI Edits & Modifier 59: Version 31.2
Date: June 26,2025
Medicare Plan of Care Changes for 2025
The Centers for Medicare and Medicaid Services (CMS) has finalized changes to the initial certification requirement for outpatient physical, occupational, and speech therapy services. In this article, I will answer the following questions:
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Hi Rick, if a Dr sends over order for therapy for 3x a week for 4 weeks but therapist would like to do initial POC for 3x a week for 6 weeks do we need to get a signature on that POC or will just sending it over count as certified?
Thanks!
You would follow the therapist established POC unless amended by the physician/NPP.
Hi, Are the Medicare Advantage plans that required a signed POC now following the new guidelines? United, Univera, Aetna, IHA and Wellcare?
Please read the answer to the question – Does this change apply to Medicare Advantage plans
Hi Rick,
Do we still have to send over the evaluation to the referring provider? Is the only thing that is changing is that we do not need the initial POC signed?
Please read the answer to the first question regarding what must be sent to the physician.
I appreciate your help. So if the original Medicare plan of care is for PT 2 times per week for 6-8 weeks, would a recertification need to be completed at the 8 week mark or the 90 days? And that recertification would require a Physician signature? Thank you.
I would not use ranges. If you said the duration was for 8 weeks in your POC, then you would need a recertification after 8 weeks.
Hi Rick, We are trying to figure out a way to reduce the burden on our front desk staff when working the queue for signatures. Do you think if the note and plan of care are visible within the EMR system for an internal doc that is enough to consider it “delivered.” Or would it need to be send via In Basket to be reviewed?
Not a question I can answer due to liability. You need to show evidence the POC was sent to the physician.
Hi Rick, In the NGSMU Therapy Billing webinar on 2/13/2025, they stated that the change to initial certification referring provider signatures using the written order effective 1/1/2025 was considered a certification exception process and should not be considered routine practice (i.e., We should continue to obtain certification signatures for initial POCs as standard practice). Is this your understanding as well?
No!
Questions: Does the Medicare program recognize direct access for outpatient therapy services?
What do you mean by direct access?
Direct Access means a patient can come to OP therapy without the need of a physician referral/order or a signed and dated plan of care.