Unprecedented”- are you tired of hearing this word?  COVID-19, The Public Health Emergency (PHE), Waivers, PPE, etc. If these times aren’t hard enough for health care providers, another blow to our sector is a hit to the CY2021 Physician Fee Schedule Proposed Rule was published on August 17, 2020. This proposed rule is open for comments and will close on October 5, 2020. Contained in the proposed rule are major provisions in the following areas:

  1. Conversion Factor Update
  2. Evaluation and Management Code Changes
  3. Therapy Assistants and Maintenance Therapy
  4. Telehealth and Communication Technology-Based Services
  5. Remote Physiologic Monitoring Services

As a therapy industry, we are extremely grateful that CMS has proposed to allow Physical Therapists and Occupational Therapists to utilize their professional judgment to delegate the performance of Medicare Part B maintenance therapy services to Physical Therapist Assistants (PTAs) and Occupational Therapy Assistants (OTAs).  During the PHE, this policy was enacted on an interim basis. Another positive is the proposed rate increase to therapy evaluation CPT codes:

CPT CodeDescription2020 Payment2021 Proposed Payment RateChange
97161PT eval, low complexity$87.70$95.179%
97162PT eval, moderate complexity$87.70$94.858%
97163PT eval, high complexity$87.70$94.858%
97164PT re-evaluation$60.27$62.527%
97165OT eval, low complexity$93.11$97.435%
97166OT eval, moderate complexity$92.75$97.105%
97167OT eval, high complexity$92.75$96.784%
97168OT re-evaluation$64.24$65.812%

Even though the increase rate in the evaluation codes is welcomed, the proposed cut on other therapy codes is shocking. And do not forget, in CY2022, therapy services provided by PTAs and OTAs will only be reimbursed at 85% of the Physician Fee Schedule. Yikes!

CPT CodeDescription2020 Payment2021 Proposed Payment RateChange
92507Speech/hearing therapy$81.20$71.94-11%
92526Oral function therapy$89.50$80.01-11%
92610Swallowing function evaluation$89.14$80.97-9%
97032Electrical stimulation$15.16$13.87-8%
97035Ultrasound therapy$14.80$13.55-8%
97110Therapeutic exercises$31.40$28.07-11%
97112Neuromuscular re-education$36.09$32.58-10%
97116Gait training therapy$31.04$28.07-10%
97140Manual therapy$28.87$25.81-11%
97530Therapeutic activities$40.42$36.45-10%
97535Self-care management training$35.01$31.29-11%
97542Wheelchair management training$33.92$30.32-11%
97760Orthotic management and training (initial encounter)$50.53$46.78-7%
97763Orthotic/prosthetic management training (subsequent encounter)$54.13$51.62-5%
G0283Electrical stimulation other than wound$14.07$12.26-13%

And if this is not enough, CMS is not proposing to permanently allow Physical and Occupational therapy services to be conducted via telehealth, even though they proposed the addition of other services to the permanent telehealth list. Residents in Skilled Nursing Facilities (SNFs) and Senior Living Communities, as well as Medicare Part B patients who would have gone to an outpatient therapy clinic for therapy services, are currently receiving medically necessary Physical, Occupational, and Speech Language Pathology services via telehealth due to the flexibility under the PHE.   

These rate changes are not all about the money folks; it is about access to care! Proposed cuts such as these are devastating without a PHE and proposing cuts, not to mention tying our hands without the permanent addition of telehealth, only increases the challenge of ensuring Medicare residents and patients receive medically necessary therapy care to improve or maintain functional abilities and quality of life.

Advocate for our Medicare Part B residents, patients, family members, and friends!  Please make your voices heard!

Functional Pathways is actively involved with The National Association in Support of Long-Term Care (NASL), a well-known and well respected advocacy group for therapy and other ancillary services. Our involvement allows us to be on the forefront of issues in the industry and to be a part of the solution. NASL has developed a link to help us contact our members of Congress urging them to oppose these proposed devastating cuts!  Click here. The time to act is NOW!!