Start of a New Year

January 2, 2018
Rick Gawenda

With the beginning of a New Year, I often receive the following questions regarding patients that were being seen for outpatient therapy in December and continue to receive therapy in January of the new year:

  • Do I need to perform and bill for an evaluation or reevaluation on the patient’s first visit in January?
  • Do I need an updated signed plan of care if the patient has traditional Medicare?
  • Do I need an updated physician order for my non-Medicare patients?
  • Must I report the functional limitation reporting G-codes on the patient’s first date of service in January?
  • If I was using the KX modifier on a patient in December, do I continue to use the KX modifier on their January claims?


Do I need to perform and bill for an evaluation or reevaluation on the patient’s first visit in January?


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  1. There seems to be some questions regarding therapy caps between private practice and hospital outpatient for the new year. APTA apparently sent out an email blast that stated:

    Hospital OPs were not originally included under the therapy cap when it was first enacted as part of the Balanced Budget Act (BBA) in 1997. Hospital OPs were subsequently added to the cap exceptions process in 2012.

    Since the exceptions process expired on December 31, 2017, the requirement for hospital OP to participate in the therapy cap exceptions process also expired.

    Is that true or their interpretation of CMS Pub 100-04 Chapter 5?

  2. Hi Rick. We are not seeing a CCI edit for the new cognitive code G0515 with the other codes that used to edit with 97532. Should we consider that the same edits as previously noted will be in effect for this new code?

  3. Hi,
    Is there a $3700 threshold anymore or is the cap just $2010, period, no more, patient is financially responsible? I’ve been reading different sites and they all say something different.
    Thank you.

    1. As of January 11, 2018, there is no $3700 threshold. That most likely will change in the near future.