CMS Final Rule: A Quick Look

The CMS final rule is out and we are going to take a quick look at some of the updates for the year. As every year there are quite a few changes. We wanted to take some time to highlight some of the biggest changes that will impact our clinics directly.

We want to make sure all Systems4PT members have the ability to maximize their MIPS participation. We will start off talking about the new addition and removal or MIPS measures. These changes will be taking place in 2022.

The first set of changes are about MIPS code changes additions and removals.

One of the first changes is the removal of quality measure 154 “Falls: Risk Assessment”. This measure is proposed for removal for 2022. This means that this measure will be removed for all documentation going forward. Our system will automate this process for all clinics to ensure you are able to maximize your MIPS participation.

Another change directly MIPS related is the addition of a new quality measure for PTs. Measure 050 “Urinary Incontinence: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older”. We know this measure will not work for every patient or work as a replacement for Measure 154. We will have alternative methods to ensure all of our clinics will still be able to maximize their MIPS participation.

The next change is about the 15% payment reduction to PT and OT service that are provided in whole or in part provided by a PTA or OTA.

The CQ and CO payment modifiers that you have been using for the last two years will now have the payment adjustments starting January 1st 2022. These codes are to be used for services provided in whole or in part by PTAs and OTAs. These payment modifiers are required for all claims starting January 1 2020 as specified in the final ruling in 2020. The 15% payment reduction will be applied to all claims that use the CQ modifier (for PTAs) and the CO modifier (for OTAs).

  • CQ modifier: Physical therapy services furnished in whole or in part by PTAs.
  • CO modifier: Occupational therapy services furnished in whole or in part by OTAs.

The following is an example of use from the CMS final rule document. “For example, if
the PT/OT and/or the PTA/OTA, as appropriate, furnished between 8 minutes through 22
minutes, one unit can be billed; if 23 minutes through 37 minutes are provided, 2 units can be
billed; if 38 minutes through 52 minutes are furnished, 3 units can be billed. Once the total
number of units to bill is determined, the qualified professional (therapist or assistant) then needs
to decide whether the CQ/CO modifier is applicable.”

If you would like a more in-depth look at all of the CMS changes use the following link to download the entire document.

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