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2020 Medicare Final Rule Released

Medicare's 2020 Final Rule Has Been Released

The 2020 CMS (Centers for Medicare & Medicaid Services) final rule has been released and there are definitely implications for physical therapy practices. This is a rule is hot of the presses. More details will come as the document can be reviewed.

There are main areas that are of interest to private physical therapy and occupational therapy practices are:

PTA/OTA modifier requirements
MIPS
2021 Fee Schedule
Dry Needling

Keep reading to learn more about where these areas of interested ended up in the final rule.

PTA/OTA Modifier and Reimbursements

CMS states that it received almost 9,000 comments in response to the proposal, many coming from physical therapy practices. The modifier is starting 2020 and the payment adjustment will start in 2022, that hasn’t changed from the proposed rule. The good news is that it has responded to several of those comments and made some changes in course that will be very important.

  • Services provided in tandem (concurrently) by PT/PTA or OT/OTA will be considered furnished by the therapist
  • Units can now be billed on separate lines to allow for the CQ/CO modifier for some units but not all of a code
  • The documentation requirement to say whether a code was furnished entirely by the therapist or aby the assistant has not been finalized and will NOT be required. Application of the modifier along with customary solid documentation will be sufficient.
  • The order of modifiers (e.g. CQ before GP) will not be an issue. Medicare contractors will re-order modifiers automatically.

2020 MIPS Highlights

Most of 2020 MIPS looks the same as 2019 with the exception of quality report and improvement activities increased reporting requirements. One interesting change from the proposed rule is that the ratio of scores shifting from Quality to Cost will not be happening, as reflected below (originally Quality was set to decrease in weight and the Cost category to increase).

MIPS Eligibility

• Low-Volume Threshold (LVT)
• Eligible Clinician Types
• Opt-in Policy
• MIPS Determination Period

 NO CHANGE

Data Collection and Submission

• MIPS Performance Period
• Collection Types
• Submitter Types
• Submission Types
• CEHRT Requirements

 NO CHANGE

Quality Measures

• Topped-Out Measures
• Measures Impacted by Clinical Guideline Changes

 NO CHANGE

MIPS Scoring

• Measure, Activity and Performance Category Scoring Methodologies
• 3 Point Floor for Scored Measures
• Improvement Scoring
• Bonus Points:
— Small Practice Bonus
— High-Priority Measures
— End-to-End Electronic Reporting

 NO CHANGE

Changes that are happening:

  • Increased QUALITY reporting requirements. You must now report on 70% of your Medicare patients for quality (claims) or 70% of ALL of your patients (registry)
  • Some new measures are being added
  • Increased Improvement Activities requirements in terms of the number of clinicians needing to participate

2021 Reimbursements for Physical Therapy and Occupational Therapy

Deep inside of the final rule, Medicare has also finalized changes to how codes are valued for physical and occupational therapy. There is a table in the final rule that indicates that the combined impact of these changes could be 8% for PT and OT. However, the detail of the codes that will be impacted is not yet available.

We remind stakeholders that although the estimated impacts are displayed at the specialty level, typically the changes are driven by the valuation of a relatively small number of new and/or potentially misvalued codes.

- CMS' 2020 Final Rule

The above quote comes directly from the final rule. Unfortunately, it’s very difficult, if not impossible, to understand the impact without seeing the codes and those will not be seen until the 2021 proposed rule comes out (Approximately in July of 2020) . CMS did not feel that the comments it received were sufficient to hold off from finalizing this change. We’ll certainly be keeping an eye on this for any indications as to where CMS is headed. Many other provider types were included on the list, as well.

Dry Needling

CMS has approved 2 new billing codes for dry needling but declined to designate them as therapy services and reversed course on designating these codes “always therapy” codes. CMS did state that if the codes were to become a “therapy procedures” in the future, the “sometimes therapy” designation would make more sense. In the end, CMS did not designate these codes a “therapy procedure” at all (sometimes or always). CMS will not reimburse for these codes in 2020.

The Bottom Line

MIPS looks to be very similar in 2020 as it was in 2019. The PTA/OTA modifier is coming but with some changes that make it somewhat better than what was originally proposed. The changes keep coming but with the right information, you can stay up on these new requirements. Stay tuned to our blog for more updates…

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