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What are the New Documentation Requirements CMS is Proposing

CMS is proposing a new documentation requirement effective with dates of service on and after January 1, 2020 to support the application or non-application of the CQ/CO modifier for each service furnished that day. In the proposed rule, CMS provides the following examples:

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Lets now take a look at some case scenarios and see when and when not the CQ/CO modifiers would be required per the proposed rule Also, keep in mind that the scenarios could change when the final rule is released in early November 2019.

Evaluations and Reevaluations

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When Multiple Units of the Same 15-Minute Time-Based CPT Code are Billed

Many times, providers of outpatient therapy services bill multiple units of the same 15-minute CPT code for services rendered to a Medicare beneficiary. I will provide several examples of how the CQ/CO modifier will or will not apply. I will use therapeutic exercise (CPT code 97110) for my examples. In addition, this is where the CMS interpretation of service will cause financial issues for providers of outpatient physical and occupational therapy.

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When Different 15-Minute Time-Based CPT Codes are Provided

I will provide several examples when the PT/OT and PTA/OTA are providing different interventions and procedures to a Medicare beneficiary that are described by different CPT codes.

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Group Therapy (CPT Code 97150)

I will provide several examples when the PT/OT and PTA/OTA are providing group therapy in which a Medicare beneficiary is a participant.

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To access the proposed rule regarding the PTA/OTA modifiers, click

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How to Bill for Services Provided By a PTA or OTA

A question I often receive is how do I bill for services provided to a Medicare or non-Medicare beneficiary that were provided by a physical therapist assistant (PTA) or an occupational therapy assistant (OTA). The answer to the question depends upon your practice setting.

In a private practice setting (you submit claims on a 1500-claim form to the insurance carrier), the services of a PTA or OTA are billed

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