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:
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
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.
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.
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.
To access the proposed rule regarding the PTA/OTA modifiers, click
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On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for calendar year (CY) 2020 for services paid under the Medicare Physician Fee Schedule (MPFS). This proposed rule does impact providers of outpatient physical, occupational and speech therapy services in all outpatient therapy settings that does include private practices, hospital outpatient departments (including Medicare beneficiaries under Observation status and in the Emergency Department and do not get admitted to the hospital), skilled nursing facilities, rehabilitation agencies, comprehensive outpatient rehabilitation facilities and home health agencies providing outpatient therapy in a Medicare beneficiaries home.
Highlights of the proposed rule include:
- Proposing to revise the regulations at §§ 410.59 and 410.60 discussing the annual therapy threshold, use of the KX modifier, and the targeted medical review threshold
- CQ/CO Modifiers to be appended to CPT codes for services provided in whole or in part by a PTA or OTA
- To add a requirement that the treatment notes explain, via a short phrase or statement, the application or non-application of the CQ/CO modifier for each service furnished that day
- PTA and OTA Payment Changes in 2022
- New CPT codes for trigger point dry needling
- New Biofeedback CPT codes
- New Health and Behavioral Assessment and Intervention CPT codes
- Discussing the 2 new Cognitive Function Intervention CPT codes
- Work relative value unit (RVU) for CPT codes 97597 and 97598
- Proposing an Active Status for CPT codes 97607 and 97608
- Proposing a work RVU of 0.40 for CPT code 97610
- Online Digital Evaluation Service HCPCS Level II Codes
- 2020 Medicare Physician Fee Schedule Conversion Factor
- 2020 MIPS Program
Revising Regulations at §§ 410.59 and 410.60
CQ and CO Modifiers
de minimis Standard for CQ and CO Modifiers
Documentation Requirements to Support Use of or Non-use of CQ/CO Modifiers
PTA and OTA Payment Changes in 2022
New CPT Codes for Trigger Point Dry Needling
Biofeedback CPT codes
New Health and Behavioral Assessment and Intervention CPT Codes
Cognitive Function Intervention CPT Codes
CPT Codes 97597 and 97598
CPT Codes 97607 and 97608
CPT Code 97610
Online Digital Evaluation Service
When you see the letter “X” in a new CPT code, this “X” will be replaced by the actual number that is in the CPT code once the American Medical Association (AMA) releases the 2020 CPT codes in early September. The same is true with the letters “NPP” in the 3 new HCPCS codes described above. These letters will be replaced by numbers once the AMA releases the 2020 CPT codes in early September.
2020 Medicare Physician Fee Schedule Conversion Factor
I hope you found this article informative. To access the proposed rule, click
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