TRICARE Implements CQ and CO Modifiers

April 23, 2020
Rick Gawenda

Effective with dates of service on and after April 16, 2020, TRICARE recognizes physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) as TRICARE-Authorized Providers. On April 22, 2020, TRICARE updated their Policy Manual to include PTAs and OTAs.

Highlights of the Policy Manual update include the following:

  • Scope of practice of a PTA and OTA
  • Supervision requirements of the PTA and OTA based on practice setting
  • Reimbursement for services provided by a PTA or OTA
  • Application of the CQ and CO modifier when services are provided in whole or in part by a PTA or OTA, respectively
  • Payment differential when services are provided in whole or in part by a PTA or OTA compared to if the service was provided by a physical therapist or occupational therapist

To access the Policy Manual, click

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  1. Do the CO/CQ modifiers apply to outpatient services furnished in a critical access hospital (CAH) when an assistant sees a Tricare beneficiary?

    1. You would need to ask TRICARE if they are following Medicare’s instructions exactly. If yes, then the answer to your question would be no. In addition, are you paid under the CHAMPUS Maximum Allowable Charge? If not, then my opinion is that it would not apply to a CAH, but it’s your responsibility to verify that with TRICARE.

  2. I practice in a pediatric outpatient private practice clinic. We do not see Medicare patients but do Medicaid. How does the CO/CQ modifiers and supervision requirements apply to this venue? Thanks for your thoughts and for sharing this information!

    1. TRICARE does not apply to Medicaid. You will need to follow the Medicaid billing rules and regulations.

  3. In the Tricare manual there is a statement about PTs certifying that the PTA provided services, etc. Does this mean the documentation completed for each treatment session by the PTA needs a co-signature by the PT?

    1. You would want to submit that question to your TRICARE contractor. Essentially, what TRICARE is saying is the PT is responsible for the services provided by the PTA and by the PT submitting the claim for payment, they are saying all of the documentation, billing and supervision requirements have been satisfied.

  4. In Southern California I am contracted with Tricare, and Health Net is the administrator. We are eager to share our PT and OT case load with some of our great assistants. Before billing we are attempting to get verbal confirmation that this regulation is being followed and reimbursed. Yesterday (5/18/2020) we spoke with a Health net representative from credentialing and they are claiming “they have no information on the use of a PTA or COTA.” We sent them the copy of the federal register from March 17th (Pages 15061-62) and the April 24th APTA PT in Motion Bulletin. Is there any deadline in which they are responsible to begin reimbursement for a PTA/COTA? Do you have any advice on how to progress with this process?
    Thank you

    1. The effective date was April 16, 2020.When will the 2 TRICARE contractors update their policy manual would be something you need to ask them.