Rehab therapists may be facing a pay cut in 2021, but at least it won’t be as high as they were originally expecting, thanks to the Consolidated Appropriations and COVID-19 Relief Act of 2021, signed December 27, 2021.1 The final 2021 Medicare Physician Fee Schedule (MPFS) rules announced by the Centers for Medicare & Medicaid Services (CMS) in early December had increased the relative value units (RVUs) for office/outpatient evaluation and management codes as well as other services, which necessitated a 9% reduction in pay for rehabilitation services.
Fortunately, Congress stepped in and provided a 3.75% increase to the dollar conversion factor and also delayed other policies, which will lessen the impact of CMS’ RVU changes on rehab therapy pay. While there will still be a decrease in payment for outpatient therapy for Medicare patients, it will be much less than CMS’ estimate of minus 9%. The actual impact on each therapist and practice needs to be estimated based on their own Medicare billing history and the new payment rates after the Congressional action. However, it is estimated that rehab therapists are now facing pay reductions of 3.3% to 3.6%.2 Hospitals are also impacted because when hospitals bill outpatient services of employed therapists, psychologists, nutritionists, etc., the payment made by Medicare to the hospitals is from the physician fee schedule rather than from the hospital outpatient payment system.
Other MPFS rules impacting rehab therapists include:
Clarification on Coverage of Telehealth and Virtual Services Post-PHE
While expected, nevertheless it is disappointing that CMS makes it clear that it does not have authority to continue telehealth benefits for patients in homes or in originating sites in urban areas after the end of the public health emergency (PHE). Congressional action will need to be taken to continue telehealth to Medicare patients in homes and in non-rural areas and to enable therapists to continue furnishing therapy services via telehealth beyond the PHE.
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A bright spot is that CMS will be able to continue supporting virtual check-in services that can be furnished to patients in homes and urban/rural locations at all times. What this means is CMS will continue to pay rehab therapists, physicians and non-physician practitioners (NPPs) for virtual services beyond the PHE. To differentiate virtual services of therapists and other clinician types from physicians and NPPs, CMS established new HCPCS codes (i.e., G2250 and G2251) for billing virtual check-in services beginning January 1, 2021. During the PHE, these services can be furnished to new and established patients, but once the PHE ends, virtual services are only enabled for established patients.
Helpful New Rules for Medical Documentation
For medical record documentation, CMS clarified that not only physicians and NPPs, but also therapists and other clinicians, such as licensed clinical social workers, will now be able to review and verify documentation by any members of the medical team caring for a patient. This change will lighten the load for clinicians, making it easier for rehab therapists to improve efficiencies and even have time to see more patients.
Documentation by team members would need to support the codes of the billing professional’s services. Documentation that can be reviewed and verified includes that made by therapy students, and students of other disciplines, working under any other physician or practitioner or therapists who furnishes and bills directly for their professional services, so long as the documentation is reviewed and verified (i.e., signed and dated) by the billing physician, practitioner, or therapist. In facilities, this may require that medical record policies be updated.
Expansion of Responsibilities for Rehab Therapy Assistance
Finally, another flexibility CMS finalized is that when a patient’s plan of care transitions to maintenance therapy, physical and occupational therapists can delegate the performance of the maintenance therapy services to physical therapy assistants and occupational therapy assistants. This will expand the reach of therapists to patients working towards improvement in functioning while helping patients needing maintenance therapy.
Confirmation of Rehab Therapy Coverage Caps
CMS also announced the 2021 threshold amounts as $2,110 for physical therapy and speech-language pathology services combined and $2,110 for occupational therapy services. The accumulated outpatient therapy amount will be reset to zero for each beneficiary beginning January 1, 2021 and therapy service payments made for each beneficiary will be summed and once the thresholds are met, modifier KX is needed for any therapy services billed to attest to the medical necessity of the services which ensures payment for the services above the threshold.
Overall, CMS’ policies fall short of providing rehab therapists with the needed flexibilities to furnish their services using technology versus in-person after the PHE ends. Telehealth could still be a safer, better option in some cases, such as for infection control, or to provide a solution for a myriad of other reasons that could create barriers to rehab therapy care.
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1-2 H.R. 133 (116th): H.R. 133: Consolidated Appropriations Act, 2021 (Including Coronavirus Stimulus & Relief)