Rehab Industry Changes for 2021
By: Cheryl “Chae” Dimapasoc Canon, PT, DPT; OptimisPT Director of Implementation and Compliance
January 1st is right around the corner, so we wanted to make sure that you are aware of any changes that may need your attention in the rehab world. We’ve pulled together information regarding some of the more important changes occurring in the new year.
Final Changes to the Medicare Physician Fee Schedule for Calendar Year 2021
(Changes will be automatic in OptimisPT)
- Conversion factor: $32.4085 a reduction of $3.6811 from the CY 2020 conversion factor (Table 104)
- RVU for CPT codes 97061, 97062, 97063, 97065, 97066, 97067: increase 1.2 to 1.54
- RVU for CPT codes 97064 and 97068: increase 0.75 to 0.96
- RVU for CPT code 92521: increase from 1.75 to 2.24
- RVU for CPT code 92522: increase from 1.5 to 1.92
- RVU for CPT code 92523: increase from 3.0 to 3.84
- work RVU of CPT code 92524: increase from 1.5 to 1.92
- 2021 Medicare $ Amount for the thermometer: $2110
So what does this mean?
The reduction is being implemented through application of the budget neutrality adjustment to the conversion factor to satisfy the budget neutrality requirements of 1848(c)(2)(B)(ii) of the Social Security Act. The combined impact of the reduction slated for physical therapy, occupational therapy, and speech-language pathology services in 2021 is -9%.
A bill to offset the cuts is still in play! Check out this APTA article for great updated information.
CPT Code Changes
2021 CPT code set changes include 206 new codes, 54 deletions, 69 revisions.
Therapy Assistants Furnishing Maintenance Therapy
In the CY 2021 PFS Final Rule, CMS finalized the Part B policy for maintenance therapy services that was adopted on an interim basis for the Public Health Emergency (PHE) in the May 1, 2020 COVID-19 IFC (85 FR 27556). This finalized policy allows physical therapists (PT) and occupational therapists (OT) to delegate the furnishing of maintenance therapy services, as clinically appropriate, to a physical therapy assistant (PTA) or an occupational therapy assistant (OTA). This Part B policy allows PTs/OTs to use the same discretion to delegate maintenance therapy services to PTAs/OTAs that they utilize for rehabilitative services.
Medicare Telehealth Services
Category 3 describes services added to the Medicare telehealth list during the Public Health Emergency (PHE) for the COVID-19 pandemic (COVID-19 PHE) that will remain on the list through the calendar year in which the PHE ends.
PT, OT and SLP service codes reside in the category 3 list:
- CPT codes 97161-97168
- CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507
Win: CMS Will Lift Several Code Pairing Restrictions
Therapy services have required the 59 or X modifier — which means that if both services are performed on the same day only the first is paid for, and a modifier is needed to indicate both codes are distinct and separate. In the new edit set that will take effect on Jan. 1, many of these problematic code pairs have been resolved. The retroactive change applies to both office and facility-based settings.
The code pairing restrictions deleted in both office and facility-based settings include:
- 97110 with 97164
- 97112 with 97164
- 97113 with 97164
- 97116 with 97164
- 97140 with 97164
- 97150 with 97164
- 97530 with 97116
- 97530 with 97164
- 99281-99285 with 97161-97168
- 97161-97163 with 97140
- 97127 with 97164
- 97140 with 97530
- 97530 with 97113
Per the APTA website, in its announcement, CMS says that some of the positive changes are retroactive to Oct. 1, 2020, with others retroactive to Dec. 31, 2019. APTA has reached out to CMS and its NCCI contractor to get more answers on the deletion dates and provisions that could allow reprocessing of previously denied claims. The association also will update the code pairing chart available on its Medicare National Correct Coding Initiative webpage.
For rehab therapists (PT, OT, SLP), Cost and Promoting Interoperability Categories are not being reported, and the value for those categories are reweighted to the “Quality” category.
The % remains the same as from Performance Year 2020:
- Quality: 85%
- Improvement Activities: 15%
Performance Threshold: 60 points (neutral adjustment) (increased from 45 points in 2020)
Additional Performance Threshold: 85 points (exceptional bonus)
There have been no changes to the Quality Process Measures (i.e. BMI, Falls, Medication Verification, etc) for PT, OT and SLP. You will still choose 5 process measures and 1 outcome measure if you are reporting via a QCDR like FOTO or PTOR.
Expect to see a considerable number of changes in 2022 for MIPS. Stay tuned!
The information we have compiled is meant to be an overview of some of the most important changes occurring for our industry. This not an all inclusive list, but it should assist in making you aware of the most important changes coming in 2021.