Trinity Rehab, LLC

Last week, CMS issued their 2025 Physician Fee Schedule Proposed Rule. These rules will apply to any therapy services provided in an outpatient/Med B setting, including outpatient clinics, skilled nursing facilities, and home health. Below are a few updates that facility-based therapists and billers should be aware of if the rule becomes final for 2025 later in the year. Payment Rate Update CMS proposes a conversion factor of $32.36, which represents a decrease of $0.93 (or 2.80%) from the current CY 2024 conversion factor of $33.29. Average payment rates are proposed to be reduced by a net 2.93% in 2025 compared to the average amount these services are being paid for most of 2024. Annual Therapy (KX Modifier) Threshold Every year, CMS establishes a revenue threshold that, when exceeded, a KX modifier must be applied to each billed service line to indicate that services remain skilled and necessary. For 2025, that annual threshold amount is $2410 for physical and speech therapy COMBINED and a separate $2410 for occupational therapy. Therapy Plan of Care Certification by Physicians/Extenders Currently, CMS requires outpatient therapy plans of care to be certified (signed and dated) by a physician or extender within 30 days of the start of care date. The 2025 Rule proposes that, if a patient presents with an order that is signed by the physician/extender indicating the specific therapy discipline and evidence can be submitted showing that the therapy plan of care has been delivered to the physician/extender within 30 days of the start of care date, that the order will suffice for physician/extender certification of therapy services without the plan of care being signed. While the presence of a valid order OR a certified plan of care within 30 days should be sufficient to get the outpatient claim paid, I still think it is best practice to have both to ensure compliance. In the Proposed Rule, CMS is also soliciting provider comments regarding regulations for timeliness of physician/extender changes to therapist-established plans of care and a 90 day time limit for the time period between the initial order and the start of therapy. Updates to Telehealth Currently, certain outpatient physical, occupational, and speech therapy codes can be delivered via telehealth through December 31, 2024. The Proposed Rule does nothing to extend this provision, so further Congressional action would be required for telehealth services to be extended into January 2025. On January 1, 2024, CMS added 3 new CPT codes for caregiver training (97550, 97551, and 97552). The 2025 Proposed Rule would add these three codes to the approved list of codes that can be delivered via telehealth, as long as those services are approved beyond December 31, 2024. The Proposed Rule can be found at https://lnkd.in/g3An5iXH. And comments are due to CMS by 5:00 PM on September 9, 2024.