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CMS Proposed Rule Revisions for Calendar Year 2020: Part Two

StrataPT,

CQ and CO modifiers

As the year 2020 quickly approaches, there are proposed CMS revisions that may affect your physical therapy’s billing procedures.  In this article, we will examine the CQ and CO modifiers that were established in the Calendar Year 2019 Physician’s Fee Schedule (CY 2019 PFS).  However, gray areas still existed and the new CMS rules look to clarify these situations.

First of all, let’s look at the CMS definitions of these modifiers:

CQ Modifier:

Outpatient physical therapy services furnished in whole or in part by a physical therapist assistant.

CO Modifier:

Outpatient occupational therapy services furnished in whole or in part by an occupational therapy assistant.

According to the CMS:

CQ and CO modifiers are required to be used when applicable for services furnished on or after January 1, 2020, on the claim line of the service alongside the respective GP or GO therapy modifier to identify services furnished under a PT or OT plan of care.  

The CQ and CO modifiers will trigger application of the reduced payment rate for outpatient therapy services furnished in whole or in part by a PTA or OTA, beginning for services furnished in CY 2022. 

The CQ and CO modifiers would not apply to claims for outpatient therapy services that are furnished by, or incident to the services of, physicians or nonphysician practitioners (NPPs) including nurse practitioners, physician assistants, and clinical nurse specialists.

Implementation of CQ & CO Modifiers

However, in response to public comments, there was no finalization of the proposed definition of “furnished in whole or in part by a PTA or OTA” as a service for which any minute of a therapeutic service is furnished by a PTA or OTA.  Instead, they finalized a de minimis standard under which a service is considered to be furnished in whole or in part by a PTA or OTA when more than 10 percent of the service is furnished by the PTA or OTA.  The ruling also states that the CQ and CO modifiers would not apply to claims for outpatient therapy services that are furnished by, or incident to the services of, physicians or non-physician practitioners (NPPs) including nurse practitioners, physician assistants, and clinical nurse specialists.

This means that only therapists and not therapy assistants, can furnish outpatient therapy services incident to the services of a physician or NP; and, the new PTA and OTA modifiers cannot be used on the line of service of the professional claim when the rendering NPI identified on the claim is a physician or an NPP

Under the new proposed policy, therapists or therapy assistants would apply the therapy assistant modifiers to the timed codes by first following the usual process to identify all procedure codes for the 15-minute timed services furnished to a beneficiary on the date of service, add up all the minutes of the timed codes furnished to the beneficiary on the date of, decide how many total units of timed services are billable for the beneficiary on the date of service, and assign billable units to each billable procedure code.  The therapist or therapy assistant would then need to decide for each billed procedure code whether or not the therapy assistant modifiers apply. 

Please note, the CQ/CO modifier does not apply if all units of a procedure code were furnished entirely by the therapist; and, where all units of the procedure code were furnished entirely by the PTA/OTA, the appropriate CQ/CO modifier would apply.  When some portion of the billed procedure code is furnished by the PTA/OTA, the therapist or therapy assistant would need to look at the total minutes for all the billed units of the service, and compare it to the minutes of the service furnished by the PTA/OTA as described above in order to decide whether the 10 percent de minimis standard is exceeded.  

If the minutes of the service furnished by the PTA/OTA are more than 10 percent of the total minutes of the service, the therapist or therapy assistant would assign the appropriate CQ or CO modifier.

Treatment Notes & CQ/CO Modifiers

Another proposed rule change would require treatment notes to include a short phrase or statement, that explains the application or non-application of the CQ/CO modifier for each service furnished that day.  Because the CQ/CO modifiers also apply to untimed services, the proposed ruling will revise the documentation requirement for the daily treatment note, extending to those codes and services as well.

This is, of course, a brief summary of the proposed rule changes that could affect you billing procedures in the near future.  While the rulings may be complicated, the solution is not. Perhaps it’s time to partner with a company that will provide you with practical systems and business solutions that you can trust.  StrataPT has been serving the physical therapy industry since 2010 and is proud to be family owned and operated. Please contact us to show you how we can simplify your business practices and allowing you more time to spend with your patients.

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