The Calendar 2024 Year Physician Fee Schedule Final Rule introduced three new Caregiver Training Services (CTS) CPT codes that became available for Physical Therapists, Physical Therapist Assistants, Occupational Therapists, Occupational Therapy Assistants, and Speech Language Pathologists to use on January 1, 2024. These new service codes allow for therapists/assistants to bill for caregiver training, without the patient present, for targeted patient populations. Currently, skilled caregiver training provided by therapists and assistants is billable only with the patient present.
This new regulation is an acknowledgement by The Centers for Medicare and Medicaid Services (CMS) that often times, with certain clinical patient scenarios, we may encounter situations where providing caregiver training without the patient present would improve the outcomes of the patient’s therapy plan of care. This is definitely a win for our physical, occupational, and speech therapy professions!
Definition of a Caregiver
In the final rule, CMS has defined the caregiver, as it relates to CTS, as “an adult family member or other individual who has a significant relationship with, and who provides a broad range of assistance to, an individual with a chronic or other health condition, disability, or functional limitation AND a family member, friend, or neighbor who provides unpaid assistance to a person with a chronic illness or disability condition”.
These codes are not approved for telehealth.
CPT 97550 is the initial 30 minutes of caregiver training in strategies and techniques to facilitate the patient’s function performance in the home or community. These activities include Activities of Daily Living (ADLs), Instrumental Activities of Daily Living (IADLs), transfers, mobility, communication, swallowing, feeding, problem solving, and safety practices. This service is provided without the patient present and must be face-to-face.
CPT 97551 is billed for any additional 15 minutes of caregiver training. This is an add-on code to 97550, meaning that we cannot bill 97551 separately without first billing 97550 (the initial 30 minutes of the training). CPT 97551 must be used in conjunction with CPT 97550 if caregiver training extends beyond the first 30 minutes.
CPT 97552 is the group caregiving training code. This code is used when providing caregiver training to multiple sets of caregivers, representing more than one (1) patient. Group is based on the number of patients represented, not the number of caregivers. At this time, there is no limit on the number of caregivers that can be in the group.
- 1 patient with 3 caregivers- not group.
- 2 patients each with 1 caregiver- group.
These codes are different than what we are used to with the CMS 8-minute rule. These codes pay using the AMA “Rule of Eights,” also known as “Mid-Point Rule”.
Rule of Eights – The AMA Rule of Eights follows the same principles as the CMS 8-Minute Rule. However, with the AMA Rule of Eights, it is calculated per service. The AMA Rule of Eights still counts units in 15-minute increments, but instead of combining time from multiple units, the rule is applied separately to each specific timed service; no remainder of minutes allowed. In other words, a unit of time is attained when the midpoint is passed.
These codes are “Sometimes Therapy Codes” and therefore, MPPR does not apply. However, when an assistant (OTA, PTA) bills these codes, they are subject to the assistant payment differential.
The physician fee schedule has not yet been updated to include these codes, so we are not sure yet what they will pay. We anticipate CMS will release soon. In addition, further clarification from CMS is needed as to whether or not the minutes billed from these codes can be included on the MDS.
Caregiver Training Services (CTS) Documentation Requirements:
Medical record documentation:
- Must include CTS codes (97550, 97551, 97552) on the PT, OT, ST plan of care.
- Must document patient consent: patient or their legal representative’s consent is required to be documented for caregiver training without the patient present.
- Must support “why” training should be completed without the patient present.
- Must document the need for each occurrence (in the Treatment Encounter Note) of CTS provided.
- Must describe the specific training that was provided to the caregiver(s).
- Must describe how the caregiver responded to the training.
- Must describe how the training impacts the patient’s goals.
- For group, document number of participants and details of the group training. Group is determined by the number patients represented in the group, not the number of caregivers in the group. Remember: caregivers are attending training on behalf of the patient.