Medicare Changes


New Therapeutic Monitoring Codes now in Medicare Fee Schedule

As of January 1st, PT’s can now bill five remote therapeutic monitoring (RTM) codes related to cost-up and monitoring of devices that measure patient therapy adherence and therapy response.  The focus of the new resource is on two sets of CPT codes: 98975, 98976, 98977, related to RTM services; and 98980 and 98981, related to RTM treatment management services. The codes were created to account for devices that allow patients to self-report, manually enter, and digitally upload non-physiologic data related to musculoskeletal system status, respiratory system status, therapy adherence, and therapy response.

Although CMS excluded PTs from using these codes in the proposed 2022 fee schedule, they made the change in the final version of the rule following hard work from APTA.

APTA has put together a practice advisory that includes background on the codes, descriptions of each, documentation requirements, and guidance on which codes are subject to payment adjustment under the PTA differential system now in place. The resource also features clinical examples to help you understand the real-world application of the codes.

Take a look!

APTA now offers a practice advisory to help you put those codes to use.





Medicare Updates

1.      Medicare and Medicaid Programs: Policy and Regulatory Revisions in response to the COVID-19 Public Health Emergency:

On July 13, 2021, the Centers for Medicare & Medicaid Services (“CMS”) unveiled a proposal to temporarily extend Medicare coverage for particular telehealth services granted during the COVID-19 public health emergency in order to evaluate which services should be covered permanently. CMS is allowing certain services to remain on the telehealth list until the end of December 312023. However, Physical Therapy is not one of them. The expansion for telehealth in Physical Therapy will expire October 21, 2021.

An Expanded Telehealth Access Act (H.R.2168) would expand the scope of providers eligible for payment for telehealth services under Medicare to include physical therapists and physical therapist assistants, as well as audiologists, occupational therapists, occupational therapy assistants, speech language pathologists, and any additional health care provider who participates in Medicare and furnishes a service that is included as a telehealth service, as specified by the Secretary of Health and Human Services. 

APTA President Sharon L Dunn, PT, PhD. States The pandemic has “made it all the clearer just how valuable telehealth is to patients who may need alternative access to therapy. It is critical that Congress make this option for therapy services permanent for Medicare patients, beyond the public health emergency.

Members, patients, and supporters can take action on the Expanded Telehealth Access Act H.R. 2168 via the APTA Action Center at:

To show your support in the Expansion act APTA advises members to assume that PTs are not recognized as telehealth providers by CMS, and the association calls on members to press the agency to expand telehealth waivers, using an APTA-developed template letter. In addition, the association is pushing for permanent inclusion of PTs in telehealth through advocacy for the CONNECT Act.

 2.     CMS Updates Guidance on Application of PTA Modifier

With PTs and PTAs about 19 months into a new Medicare rule requiring the use of a coding modifier when services are furnished "in whole or in part" by a PTA, the U.S. Centers for Medicare & Medicaid Services recently provided more guidance around exactly how those modifiers are supposed to be used — and APTA has adjusted its member resources accordingly.

CMS has provided additional details on the policy for calculating the 10% "de minimis standard" and put a set of billing examples that illustrate how the CQ modifier should be applied to indicate services provided by a PTA.

The new modifiers don't affect payment now, but they will trigger payment at 85% of the applicable fee schedule rate beginning in 2022. APTA and other organizations have opposed the payment differential, which is required by law. APTA also voiced concerns about a general lack of guidance around exactly how clinicians should use the modifiers.

To help members prepare for the change, the association created a Quick Guide To Using the PTA Modifier, which has been updated to reflect the new guidance from CMS. Like the CMS resource, the guide contains examples, and includes a handy reference chart and tips on documentation.

But that's not all APTA has to offer to help members understand both the application and background of the rule. Here are two other resources that can help fill in the gaps.

How To Apply the New CQ Modifier
This Compliance Matters article from the March issue of APTA Magazine provides a brief background of the rule before diving into just how it is applied. It also includes more scenarios to help readers get a sense of how the rule works in the real world of therapy.

The PTA Differential: How We Got Here, and What's Next
This perspective from early 2020 lays out the entire history of the differential, from its first mention in the 2018 Bipartisan Budget Act to APTA's continuous advocacy that led to a better-but-still-flawed final rule. Member David Harris, PTA, MBA, authored the piece (he's chief delegate of the APTA PTA Caucus), which is not only valuable for the history it provides but also as an example of the legislative and policymaking twists and turns that affect rulemaking.

 3.     Medicare Physician Fee Schedule proposed rule: Released July 13, 2021

The proposed 2022 conversion factor comes in at $33.58, down $1.31 from the current-year conversion factor of $34.89.

The rate cut is a result of mandated budget neutrality adjustments and the expiration of the one-year 3.75% increase that was set in motion by the Consolidated Appropriations Act of 2021.

The combined impact of the proposed 2022 conversion factor decrease is expected to see an impact of 3.5% for PT, 3.8% for ST and 3.9% for OT.

Evaluations and re-evaluations saw no change in payment. Massage saw an increase in payment. 

 4.     Clinical Practice of Parkinson Disease

APTA is developing a new clinical practice guidelines on physical therapist management of Parkinson disease. The public review phase for comments ended July 14th.

Funded entirely by APTA, the draft CPG covered topics ranging from aerobic, flexibility, and community-based exercise to resistance, balance, gait, and task-specific training. The resource was developed by a volunteer development group that included member expert PTs and a neurologist, and it was based on systematic reviews of current scientific literature, clinical information, and accepted approaches related to the physical therapist management of PD.





9% Medicare Cut reduced to 3.6%  
A message from Sharon Dunn APTA President:

After months of advocacy by APTA members, Congress partially addressed the projected 9% payment cut for physical therapist services under the Medicare Physician Fee Schedule that’s set to go into effect Jan. 1. The COVID-19 relief package, announced yesterday, includes $5 billion in offsets that will reduce the cuts from an average of about 9% to an average of about 3.6%. This relief falls well short of ensuring patient access to needed services, and a 3.6% cut threatens the viability of thousands of providers who offer safe, cost-effective care that helps older adults maintain their independence and avoid more costly procedures.


MIPS Final Rule:

Like the proposed version, the final rule from CMS keeps the Quality Payment Program mostly as-is.


NCCI Edit information - December, 2020 

CMS Releases Coding Edits With Possible Good News for PTs CMS has released the list of Medicare National Correct Coding Initiative procedure-to-procedure edits that will take effect Jan. 1, 2021. Many of the PTP edits for common physical therapy code pairs have been deleted; APTA staff are currently reviewing the files in detail to identify all the changes. One early finding: We’ve determined that the problematic edits that prohibited the billing of codes 99281-99285 with codes 97161-97164 have been deleted. We’ll share more detailed information about all the changes as soon as possible. The updated list of PTP edits can be found at the CMS NCCI coding edits page.

Sign up to Receive Updates ›  APTA

APTA CT PO Box 459
Tolland, CT 06084
(857) 702-9915