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  • Time to Act: Surprise Coding Complication Ignores Realities of PT Practice and Must be Changed

     

    NOTE: While comments to this story are welcome, if you want to add your voice to the advocacy effort, please follow the "what you can do" instructions in the last paragraph to contact the NCCI contractor directly. Thanks!

     

     The US Centers for Medicare and Medicaid Services (CMS) unveiled an unwelcome New Year's Day surprise for outpatient therapy providers, including private practitioners and facility-based settings, when it announced it will no longer allow two frequently used therapy billing codes to be used in combination with evaluation codes. It's a decision that flies in the face of standard PT practice and effective patient care—and CMS and the National Correct Coding Initiative (NCCI) contractor need to hear that perspective loud and clear, from as many stakeholders as possible as soon as possible.

    At issue are current procedural terminology (CPT) codes 97530 (therapeutic activities) and 97150 (therapeutic procedures, group, 2 or more individuals) which, until January 1, were allowed to be billed on the same day as physical therapy or occupational therapy evaluation. Under new CMS NCCI edits, however, that's no longer allowed. And in a further complication, the latest NCCI edits also require use of the 59 modifier—the modifier that's used to indicate that a code represents a service that is separate and distinct from another service to which it is paired—whenever code 97140 (manual therapy) is billed with an evaluation.

    [Editors' note: to view the full list of edits that went into effect January 1, visit the CMS PTP coding edits webpage, and scroll down to the "related links" area, where you can select your setting to find out what's changed.]

    The problem, according to APTA Director of Regulatory Affairs Kara Gainer, is that the changes ignore accepted PT practice, which often includes the startup of care on the same day as evaluation, as well as continuation of care on the same day as revaluation.

    "The whole NCCI process is supposed to put a check on payment for codes that represent overlapping services," Gainer said. "These edits not only miss that mark, they actually have the effect of restricting patient access to the most effective, efficient care, and risking a patient's ability to achieve the best possible outcomes."

    APTA usually receives notice of intended NCCI edits well in advance. That didn't happen in this case, making it imperative that the association, its members, and other stakeholders take action quickly to convince NCCI to reverse its decision. APTA is in communication with Capitol Bridge, LLC, CMS' NCCI contractor, as well as with the American Medical Association, to press for a resolution to the problem.

    What you can do: APTA has developed a comment letter template that you can fill in with your personal information and email to Capitol Bridge, LLC, at NCCIPTPMUE@cms.hhs.gov. Make your voice heard.

    Comments

    • I work in a SNF and had asked my superior if this was a technology error. We found out today it was not. What makes it worse is that it is across disciplines so that a PT/PTA cannot charge for an evaluation and an OT/COTA charge for 97530 on the same day and vice versa. This rule was not thought out by a praticing therapist and leads to potentially unethical charging practices.

      Posted by Iris Stanford on 1/2/2020 3:41 PM

    • Is this in effect as of 1/1/2020? Thank you, Chrissy Dyess

      Posted by Christina Dyess on 1/2/2020 3:51 PM

    • I am requesting that PT and OT be able to bill 97530 code on the same day as the evaluation code. PTs and OT use the 97530 code frequently as it relates to functional activities. Functional activities are commonly done on evaluation day as there is no clinical reason why these codes should no be billed on the same day. Please reconsider and allow the therapeutic activity code and evaluation code to be billed on the same day. Thank you, Chris Batchelor, PT

      Posted by Chris Batchelor, PT on 1/2/2020 3:58 PM

    • The most important thing in the medical field is making sure patients receive the best care they can in a convenient and effective (timely) manner. This new coding implicates and restricts that, which means it is preventing patients from receiving the best quality of care. We advise the NCCI to reverse this new coding decision.

      Posted by Elli Cassabaum on 1/2/2020 4:18 PM

    • These edits as proposed make it difficult for therapists to provide efficient and effective care to our patients. Please reconsider the change made to pairing evaluation codes to therapeutic activity and group therapy. Theresa Kienle PT GCS

      Posted by Theresa Kienle on 1/2/2020 4:23 PM

    • 1/2/2020 To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Christopher T. Whiteman, M.P.T. Co-owner Progressive Physical Therapy & Rehabilitation Center 11801 Upper Potomac Industrial Park St. Cumberland, MD (301) 729-3485

      Posted by Christopher T.Whiteman on 1/2/2020 4:33 PM

    • Submitted electronically: NCCIPTPMUE@cms.hhs.gov To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Carla Griffith, PT, DPT Physical Therapist

      Posted by Carla Griffith on 1/2/2020 4:42 PM

    • If something is working, it’s working. There is no reason this code malfunction should cause trouble for physical therapists everywhere.

      Posted by Mohammad Zulfiqar on 1/2/2020 4:52 PM

    • As long as we have administrators like Alex Azar and Seema Verma in office, the Department of Health and Human Services will be more focused on cost cutting than they will be on health and human services. Given this present administration, I am not surprised by the discourtesy of blindsiding the APTA with this change of practice.

      Posted by Stephen Small on 1/2/2020 5:02 PM

    • The new changes to coding delay the onset of care. Therapeutic Activities is where most PT’ s initially start treatment as appropriate to the patient. This coding denies the patient this care on the evaluation day. Not a good practice!

      Posted by Robert Pinkston PT on 1/2/2020 5:05 PM

    • CMS continues to make efforts to restrict and limit the therapists ability to provide needed care. We are regressing in the world of SNF to pre1960 when SNF where a place to essentially sustain not to maintain or improve. I understand the financial difficulties the future holds for Medicare and the “baby boomer” generation but we can’t ignore a complete generation and continue this path of regression of the quality of healthcare that can be delivered in a SNF setting. The sad reality is that therapist are more educated and better prepared to assist the aging but are being handcuffed by Medicare pinching pennies. They need to remedy this by finally taking action in big Pharma the one truly behind sky rocketing health care costs.

      Posted by Aaron Colson on 1/2/2020 5:08 PM

    • As the President and Owner of a small pediatric private practice in Chicago's suburbs, I can tell you that this decision is devastating for our parents who bring their children to us. First of all, the current levels of reimbursement for the PT evaluation codes fall FAR BELOW what is needed to compensate therapists for 2.5 hours of their time for our very complex young patients. At the present extremely low rate for even the highest eval complexity, we can only cover a half hour of service including a cursory look and very abbreviated writeup. This does not constitute a true evaluation. In the past, we would also charge for treatment codes because we would also treat during this initial visit, and in that way would get the know the child better, understand what the foundation deficits are, and be able to guide parents toward home programming from the beginning. This situation needs to be rectified immediately.

      Posted by Renee Rowley on 1/2/2020 5:10 PM

    • To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above.

      Posted by Jamie Rabe on 1/2/2020 5:11 PM

    • To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Lisa Nerem, PTA

      Posted by Lisa Nerem on 1/2/2020 5:12 PM

    • The new billing changes instituted Jan 2020, which does not allow and evaluation or re-evaluation to be billed with treatments breaks therapeutic practice. When a patient comes in for a first visit he expects to get treatment and leave feeling somewhat better. If they went to a doctor feeling sick, they would expect to get medication that day, not wait for a few days, come back and then get treatment for their ailment. It’s the same with physical therapy.

      Posted by Cindy Neiburg on 1/2/2020 5:18 PM

    • It makes no sense whatsoever to not teach functional exercise the same day as an evaluation. This measure only encourages PTs not to treat the same day as the evaluation, which isn’t in the patient’s best interests. Does Medicare not realize that they’re so often part of the problem and not the solution? What’s more this is being done without any notice. It’s no wonder that more and more PTs are electing to be out of network with Medicare.

      Posted by Karl Bebendorf on 1/2/2020 5:18 PM

    • Please look at changing these NCCI edits as they are limiting to patients that need to receive these services. To restrict the ability of therapists to provide manual therapy and dynamic therapeutic activities on the same day as an initial evaluation flies in the face of best practice standards for PT and OT. In this time of limited visits, reimbursement and increased restriction, therapists are challenged to do more with less visits. If you further restrict our ability to serve our patient population with these edits, this only costs more in the long run for all those involved. The patients do not get the services they need, the therapists are hit with needless red tape which results in increased paperwork and billing issues and the patients do not get well as quickly, resulting in more services needed for a longer length of time which costs insurance companies more. Maybe it is time to think about the ability of best practices before making needless restrictions. Thank you for your consideration.

      Posted by Leeann Plank on 1/2/2020 5:20 PM

    • It's disappointing that the patient doesn't get some of the treatment requiring the most skill, code 97140 (manual therapy) on the same day as an evaluation or re-evaluation. Patients pay into the Medicare system their entire career without any choice in the matrer and once again, get the short end of the stick. We need to stand together and request fair treatment for the patient and provider be restored.

      Posted by Erik Zamboni on 1/2/2020 5:27 PM

    • Email sent! Thanks for the notice APTA. While I don't think group therapy is appropriate on the day of eval, the rest of the changes are absurd! Let's hope we can get this changed!

      Posted by Melanie Wells -> ?IScCN on 1/2/2020 6:27 PM

    • This would be an unnecessary change to require modifier with evaluation for manual therapy treatment or the other codes.

      Posted by Shelly Walsh on 1/2/2020 6:34 PM

    • To whom it may concern, I am an evaluating occupational therapist and would like to wholeheartedly express my concerns regarding these changes. Not only are you causing chaos in therapy departments for making such a change without adequate preparation for those impacted, you are restricting evaluating therapists from utilizing hard-earned education and clinical judgement to ensure their patients get the most client-centered and appropriate care on day of evaluation and the following days when other disciplines may be initiating their evaluations. This change is unwarranted and steps on the toes of us who have worked hard to earn and maintain our licensure. Essentially, it is detrimental to our patients, their length of stay and likely to their outcomes and success rates upon discharge. Please consider reversing these changes regarding use of the Therapeutic Activity codes and truly think of what you are taking away from our patients by not doing so.

      Posted by Madolyn Frye on 1/2/2020 6:53 PM

    • These changes will impact our ability to start full care of the patient their first day with the evaluation. Often our testing can cause and increase in symptoms and being able to do manual therapy the first day is one of the things that can help them feel better. In addition to that our whole goal as therapists is to improve function and that usually begins day one with exercises for function and biomechanics that fall under therapeutic activities. By delaying the best care the first day it will drive up costs and not reduce them. Please let us give our patients the best care and reverse these decisions.

      Posted by Cari McClellan on 1/2/2020 7:40 PM

    • I don’t agree with this new regulation.

      Posted by Bethany Clark on 1/2/2020 7:51 PM

    • The surprise NCCI edits disallowing 97530 and/or 97150 with an eval/re-eval is against normal PT practice. Imagine going to a MD and all they were allowed to do was diagnose but not treat. A large majority of our patients are pain patients or post surgical patients and not allowing they to receive treatment is prolonging their impairment and could be detrimental following surgery. In addition the requirement of modifier 59 when 97140 is performed on eval day would suggest they manual therapy is a component of the evaluation- this is inaccurate. Thank you Jerry Yarborough,PT, DPT

      Posted by Jerry Yarborough PT,DPT on 1/2/2020 8:02 PM

    • It is ludicrous that one can not bill PT eval and therapeutic activity at the same treatment. What are we supposed to do? Do an eval and say “ yes you could benefit from PT but I can’t give you any PT today because your insurance won’t allow it.” Then come back the next time and finally start the PT?

      Posted by Dana kessler on 1/2/2020 8:04 PM

    • I work in a SNF. Eval day typically means an abundance of therapeutic activities. This makes no sense whatsoever and ends up in potentially fraudulent/incorrect use of CPT codes.

      Posted by Kristin Lefel on 1/2/2020 8:38 PM

    • This decision is detrimental to the patients care

      Posted by Renee card on 1/2/2020 8:40 PM

    • As a private practice owner patients come to my my clinic to get immediate help with their injuries so they can return to their work and activities pain free with functional range of motion, strength and function. Therefore after the evaluation we begin treatment right away. You would lose business if a patient had to wait a visit to get the treatment they need after their initial evaluation

      Posted by kerry D’Ambrogio on 1/2/2020 8:57 PM

    • This is so stupid. Wow! So you’re saying we need to let a patient go home after an evaluation without intervention such as therapeutic activity . What if a patient is in a severe risk for fall and injuring her/himself and ended up in the most expensive route of intervention- an ambulance bill and an expensive ER visit. Why? And where do you stand on OPIOID crises ? Would you want to be sent home after a physical therapy evaluation and wait another visit to address the musculoskeletal dysfunction using Manual Therapy on the same day? This is beyond comprehension. Very sad day for Medicare members.

      Posted by Eileen Burns on 1/2/2020 9:19 PM

    • Patient care and outcomes and allowing them to age in place is in jeopardy with these new changes. Limiting what we can do puts our patients at risk and potentially costing more money if they need to go to a hospital or a skilled nursing facility.

      Posted by Aimee Newman on 1/2/2020 9:24 PM

    • I have just started my 30th year as a PT and I cannot understand this decision. The TA code is used for home program development as it demands one on one education, at times demonstration and facilitation for proper performance. What code would you use to bill for this ? I feel like it undermines my ability to choose the correct cpt code for consistent practice. You don’t just change the code when it’s the most appropriate charge. Once again we are befuddled by the process of billing which has Taken time away from patient care today trying to figure out how to accurately charge. It is of utmost importance to me to get a home plan established during the first session.

      Posted by Holly Sabourin on 1/2/2020 9:27 PM

    • These edits not only miss that mark, they actually have the effect of restricting patient access to the most effective, efficient care, and risking a patient's ability to achieve the best possible outcomes.

      Posted by Alana Yerman on 1/2/2020 9:29 PM

    • TY for putting this out! I have been struggling to find out from Capital Bridge why they would do this to no avail and NO ONE has even made a peep about this absurd edit until now.

      Posted by ANAMARIE CUNNINGHAM on 1/2/2020 9:34 PM

    • PS: the email posted doesn't work. i emailed them 3 times thinking perhaps i had erred in the address...nope! returned all 3 times! the only way to contact them is via fax, in which you get a generic CMS owns this list we will get back to you.

      Posted by ANAMARIE CUNNINGHAM on 1/2/2020 9:38 PM

    • Medicare is not really meeting the needs of the patients regarding physical therapy, speech therapy and occupational therapy. People need treatment to recover and just providing the minimal is not good enough.

      Posted by Rosemary King on 1/2/2020 9:49 PM

    • This change in PT coding will delay necessary treatment initiation for clients a which will then delay improvement in function and return to normal activities. Inefficient and counterproductive; please review these edits.

      Posted by Barb Settles Huge on 1/2/2020 9:56 PM

    • Re restricted THERACT code on same day of evaluation. These changes actually restrict patient access to the most effective, efficient care, and risk a patient's ability to achieve the best possible outcomes. So we shouldn’t teach a patient with a lumbar fracture to log roll to safely transfer out of bed?. Just evaluate the way they are doing it as harmful!!! Please. Use some common sense when making these changes.

      Posted by Kelli Elmore on 1/2/2020 10:10 PM

    • I have a question re:evaluation and not being able to bill Ther Act along with it. What is a therapist to do when a patient is evaluated for pain after a fall in a Long Term Care Facility? You provide an evaluation and need to educate staff on the proper transfer technique to assist the patient to move with the least amount of pain? That’s just one of the many situations we see. Should we just let them suffer and prolong treatment and in the end have less effective outcomes? I don’t understand the rationale behind this other than to have more red tape and less benefits for patients.

      Posted by Jackie Lacek on 1/2/2020 10:14 PM

    • How can we effectively help our patients if we can’t teach them home safety , precautions and fall risk . Physical therapy is being neglected in the total treatment of the patient . The cost of these patients falling and needing additional hospitalization, additional surgeries etc far exceeds the $30 we get reimbursed for a unit of Therapy Activity !!

      Posted by Stephanie Enders on 1/2/2020 10:25 PM

    • This is an absurd attempt at dictating treatment that encourages foregoing patient safety.

      Posted by Melody Tran on 1/2/2020 10:53 PM

    • Please allow eval plus theraactv

      Posted by Rishu on 1/2/2020 10:55 PM

    • To whom it concerns, The adjustments made by Medicare including the use of 97530 and an eval code affect my ability to provide optimal patient care while also billing in an accurate matter. If the pt presents with poor bed mobility at IE, and a therapeutic activity can be initiated at IE to improve the pt’s functional mobility and independence (Ex:Training proper use of bed rails to optimize participation with rolling) , it is in the pt’s best interest to gain this skilled training from their physical therapist at the first encounter. With that being said, there is no way to accurately bill for what occurred during the IE, if the therapist is not allowed to bill for the 97530 code, leaving the therapist in a moral dilemma due to this activity not properly being define under any other code. Please reconsider your decision instead of limiting Medicare patient’s access to optimal care at IE. Olivia Violett PT,DPT

      Posted by Olivia Violett on 1/2/2020 11:07 PM

    • Please reassess the current decision to restrict present billing and the inappropriate interruption of therapy practice that will likely have an ineffective completion of its intended goal, but will be detrimental to patient care.

      Posted by John Chatwell on 1/2/2020 11:09 PM

    • This must be changed immediately. In a SNF setting, patients often receive initial PT evaluation with subsequent treatment on bed mobility and transfers, which must be billed as therapeutic activities (97530). The expertise of the PTs allow for assessment to be intertwined with treatment (providing education, verbal/tactile/visual cueing, and use of compensatory strategies for bed mobility and transfer training are all treatments which should be billed as that). Being able to treat patients on same day as their initial evaluation allows for better and faster positive outcomes. It benefits the patients and allows therapy to truly begin as soon as possible. Please take into consideration what the PTs are telling you in order to provide best care to the patients, which is ultimately what it is about.

      Posted by Conner Cox on 1/2/2020 11:30 PM

    • Re: Changes to Physical Therapy Billing Codes It is standard practice to perform therapeutic exercise and manual therapy in the same session where an evaluation is performed. I am in protest of disallowing this to be billed together, or to require a 59 modifier. This is not in the best interest of the consumer or the practitioner.

      Posted by Linda Whitworth on 1/2/2020 11:34 PM

    • I have a hard time understanding why insurance companies are fighting paying for rehab and preventative care that ultimately saves or lessens the costs associated with prescriptions, wound care, surgeries, equipment needs, in-home personnel, and other complications. Why do we have to time and again prove our skilled contribution when no one questions other medical professionals who don't lay hands on and just write scripts? (Not saying all of that profession are that way obviously, just pointing out that many are). We spend 30, 45, 60 minutes in person completing skilled programs, assigning home programs, and other time modifying, adapting, adjusting equipment, assisting other healthcare professionals, educating ourselves and others, etc, and yet we must needs fight tooth and nail for reimbursement. All the while, someone swabs my throat, tests it, calls it strep, writes a script and gets reimbursed no problem. I digress. We are doing a disservice if we are. Unable to start some kind of treatment day of evaluation. We should be compensated for our skills and what we deliver to the patients.

      Posted by Marie Carreras on 1/2/2020 11:35 PM

    • Trying to keep an outpatient PT practice viable is near impossible as it is with Medicare not keeping up with cost of living increases and continued reduction of reimbursement. This will only lead to more Private Practices changing to cash only practices or going out of business, which will severely reduce availability of PT services. This is just another example of how Medicare plans to cut back on spending for ancillary services.

      Posted by Michael Kelly PT on 1/3/2020 12:13 AM

    • I request CMS and NCCI reconsider their CPT code change for 2020 to allow, without modifier 59 the ability to have OT and PT use similar codes in the same day of treatment and that evaluation charges do not interfere with treatment charges the same day of service. Patients have a very short inpatient and outpatient period and need maximum care ASAP.

      Posted by Joan Belady PT on 1/3/2020 1:02 AM

    • DATE: 1/3/20 Capitol Bridge, LLC National Correct Coding Initiative Contractor PO Box 368 Pittsboro, IN 46167 Submitted electronically: NCCIPTPMUE@cms.hhs.gov To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530​​97116​​Mutually Exclusive 97530​​97113​​Mutually Exclusive 97140​​97530​​Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Lucas Grossoehme SPT

      Posted by Lucas Grossoehme on 1/3/2020 2:49 AM

    • By impeding our ability to practice most efficiently and effectively during our first encounter with a patient will end up costing insurance companies more money in the long run as these patients will not achieve the best outcomes sooner. It is also detrimental to a patient as well as unethical to withhold treatment that is a warranted.

      Posted by Lindsey Donohue on 1/3/2020 3:55 AM

    • Medicare should allow billing of 97530 and any other CPT code that maybe necessary on day of evaluation to allow patient to have best possible care for that day of service and access to medical care they deserve. I disagree with medicare rationing care which puts individuals that have Medicare a risk for further problems. I think it’s shameful that Medicare attacks PT with billing restrictions and slashing of reimbursement. From my experience PT is the most effective service for helping older individuals have the safest and best quality of life. Physical therapy has had only 2% increase for billing reimbursement over a 30 year period which is ridiculous. We are small percentage of health care (about 1.7%) but we are constantly attacked by CMS. This needs to change.

      Posted by Gregory LeMoine on 1/3/2020 5:10 AM

    • The new changes not allowing ther activity to be billed the same day as eval has put out patients at risk. For example we have a Patient who has broken their back and must learn to log roll to safely get in and out of bed and donn and doff a back brace. In this case we would be training this Patient on proper bed mobility and safety, all which is billed under ther activity and without this training this Pt is at risk of further injury. Your coding changes are telling PT’s and OT’s to not do a crucial piece of their job and not treat our patients the most efficient and effective way and put out patients at risk. We are also not allowed to Educate or train our patients in transfers on this is also billed under ther activity. Patient education is crucial and is not part of an evaluation of a patient , and allows the patient to understand and take control of their situation and perform activities or exercises the most effective way allowing a quicker and safer return to prior level of functioning. I’m not sure who decides these rules, but obviously they have not talked to a therapist who practices under these rules and thoroughly understands patient care, needs, safety, and what the codes allow us to bill for. This rule is detrimental to every patient everywhere!

      Posted by Lucinda Serr on 1/3/2020 5:31 AM

    • These coding changes appear not particularly focused on patient care versus a random way to limit payment.

      Posted by Julie Chita on 1/3/2020 6:12 AM

    • Allow for clinical judgement!

      Posted by Kali Griffin on 1/3/2020 6:49 AM

    • I am a PT practicing in a SNF. With the change of not allowing the code 97530 on day of evaluation is limiting my card to my patients. My patients are here for short term rehab to return home and limiting treatment on day of evaluation not only delays care but also delays return to home. To me this does not make sense. After my evaluation I proceed with treatment for safety with transfers, teaching of home safety, teaching of energy conservation and pending on their case whatever else they need to start the process to return home. How is this fair to my patients that now I am no able to provide a full treatment until the following day? How am I to explain this to my patients? We are trying to get our patients home to the next level of care but now we have to wait another day to start that process. When does what the patient need come back into perspective? This change is not appropriate and does need reversed as soon as possible for patient care.

      Posted by Erin Horner on 1/3/2020 7:11 AM

    • To whom It May Concern, The new billing regulation codes of 97530 and 97150 have immediately negatively impacted patient care in my setting of skilled nursing. My patients, require skilled therapy interventions including education, analysis of task demands, task upgrade/downgrade, strategies to improvise and maximize quality of life which are skills that billing code 97530 encompasses. On the contrast, 97150 code is inclusive of group therapy which could work on a number of different skills including but not limited to adaptive equipment training, home exercise program training, neuro re-Ed training, fall reduction and recovery training, the list goes on. By taking away the ability to utilize these clinical billing codes for therapists, patient care is ultimately compromised. I ask you to please reverse the changes made under CMS.

      Posted by Hannah DeSarro on 1/3/2020 7:33 AM

    • The restriction of no longer allowing physical therapists to Bill an evaluation and therapeutic activities together only hinders patients from getting the services they may need. In order for therapists to help their patients get better as efficiently as possible, these arbitrary rules need to be removed. They do not make any sense whatsoever. Therapists are burdened with various billing rules it takes time and attention away from their patients.

      Posted by Margaret Firzpatrick on 1/3/2020 8:26 AM

    • As pts are allowed less time in my facility, skilled nursing, this new rule will decrease the amount if progress they are able to make. We want to send them home in the safest condition we can. Thank you Venita Sheldon OTR

      Posted by Venita Sheldon on 1/3/2020 8:29 AM

    • This is routine physical therapy practice is necessary for effective and efficient patient care. Limiting the therapist ability to treat on evaluation and revaluation treatment sessions will not decrease the cost of care and will likely in crease the duration of treatment and increase the cost of care.

      Posted by Lawrence Risigo on 1/3/2020 8:33 AM

    • These changes are very concerning. Clinics are already struggling to continue to treat patients with Medicare coverage and those that have made an effort to do so so far are going to start bleeding money, which will directly affect practitioners. The movement toward cash-based practice is going to continue to progress and Medicare patients are going to suffer directly.

      Posted by Nadia on 1/3/2020 8:35 AM

    • I have been practicing in the industry for 30 years. It is becoming increasing difficult to perform my patient related job duties. The people responsible for making these changes certainly do not understand the delivery of PT services.

      Posted by Ann McCallum, BS, MPT on 1/3/2020 8:55 AM

    • I’m a writing to ask for immediate reversal of the new billing code changes prohibiting billing therapeutic activities 97530 and an eval code on the same day. This prohibits PTs from providing valuable and effective treatments to improve function and movement as quickly as possible during a pts. first visit. Providing a patient education on proper mobility and movement to improve function and ADLs as quickly as possible is crucial for improving a patients function as quickly as possible. An initial eval, is a great time to provide this CPT code.

      Posted by Joe Nance on 1/3/2020 9:00 AM

    • Stop this change!

      Posted by Sandy on 1/3/2020 9:01 AM

    • This is absurd and is limiting patient care!! Medicare fully understands that PT has literally saved billions in healthcare dollars but yet Medicare goes after its best ally in cost effective care, PT, and doesn’t bat an eye in paying for a total knee replacement with just an x-ray. Medicare is not doing right by the patient here and the patients are the ones that matter!!

      Posted by Parsa Karimi on 1/3/2020 9:05 AM

    • In my professional opinion, the ability to bill for therapeutic activities on the same day as an evaluation is sometimes the most important skilled activity needed that day. Some of my clients struggle to stand up from seated surfaces, and are very sedentary. I may need to instruct in sit to stand transfers as well as establish increased activity levels, by implementing a Home exercise program day one. This helps to set up the clients expectations from me, and establish carryover of learned skills throughout the course of care and beyond.

      Posted by Christine Thomas, PT, DPT , GCS on 1/3/2020 9:08 AM

    • So needed. PT has helped my family so much. Reverse this please...

      Posted by A. Legere on 1/3/2020 9:10 AM

    • These new NCCI edits will severely limit patient access, patient rights, and their continuum of care, which, in some cases, could be detrimental to patient functional outcomes and should be rescinded immediately. It also restricts practitioner autonomy in decision making which could lead to disasterous consequences as I know a lot of therapists who use their treatment times as a means of continuous assessment of patients/clients. Please resolve this issue immediately.

      Posted by Roger Brenem on 1/3/2020 9:36 AM

    • Please reverse the decision to disallow 97530 and 97150 to be billed on same day as outpatient PT eval, and eliminate the need for modifier 59 to be needed with 97140 on day of eval.

      Posted by chris hannibal on 1/3/2020 9:42 AM

    • These new CMS NCCI edits are inappropriate, unneeded and restrict quality patient care. On days of evaluation/reassessment it is imperative that we as physical therapists are able to also treat the patient to capitalize on their found information, educate and initiate the healing process. This is not only necessary in the rehabilitation process but also to reduce continued compensatory patterns and make immense changes on the pain process. Those things taking place at initial evaluation/reassessment are absolutely necessary to give appropriate quality care to our patients. Please reverse this decision so the healing of these patients, so in need of this care, is not restricted buy this edit in coding.

      Posted by Joseph P Amico on 1/3/2020 9:48 AM

    • The current edits are severely complicating my ability to provide initial treatment to compliment the evaluation and education that I provide my patient and staff on the initiation of therapy services. These edits can only compromise initial care and delay treatment. As a therapist that works diligently within the system to meet all the regulatory and financial constrictions, I find this to be an unacceptable constraint. I realistically account for my time to do a full evaluation to the depth and scope of the evaluation codes and then move on with initial treatment. This is only hurtful to my patients who need the ability to perform functional activities and basic mobility to be impacted immediately upon arrival by the direction and skilled interventions of a Physical Therapist.

      Posted by Amy Kerr on 1/3/2020 9:54 AM

    • To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Posted by Jamie Rabe on 1/2/2020 5:11 PM To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Teresa White PTA

      Posted by Teresa White on 1/3/2020 10:02 AM

    • where can we obtain more details?

      Posted by Berenice Galvez-Soto on 1/3/2020 10:21 AM

    • Our practice standard is to provide therapeutic activity training on the same day as OT evaluation. This session is 60 minutes in which the patient is evaluated and then provided therapies they can put into practice immediately. Patient care would be compromised with this change. Outpatients want training and education to improve their condition on day one. This change would require OTs to see patients for a 30 minute evaluation and then need to return for therapy. Access and patient satisfaction would be compromised. We can not afford to provide free therapy. Please help!

      Posted by Jennifer Missling on 1/3/2020 10:35 AM

    • Insurance companies are not the doctors of physical therapy. This is a disadvantage to patients everywhere and in every setting. I’m currently only a student, but the changes made in the past year, have done nothing to support best patient care and outcomes!

      Posted by Lacie Howell on 1/3/2020 11:12 AM

    • This conflicts with skilled assessments perform during evaluation in the SNF setting.

      Posted by Monique Fitchard on 1/3/2020 11:19 AM

    • This rule disallows me as a PT to begin educating and treating a patient in the Initial Eval day. This is pretty absurd to believe that CMS would disallow us to begin treatment as soon as possible

      Posted by Jeff Porter on 1/3/2020 11:22 AM

    • Please reverse this change to allow occupational and physical therapists the opportunity to provide care specific to the needs of the patient.

      Posted by Polly Wallace on 1/3/2020 11:31 AM

    • This change is not in the best interest of patients or providers. We commonly begin care on the same day as an evaluation. This will slow patient progress, delay relief of symptoms and generally interfere with evidenced based care.

      Posted by James Stephen Guffey on 1/3/2020 11:35 AM

    • January 3, 2020 Capitol Bridge, LLC National Correct Coding Initiative Contractor PO Box 368 Pittsboro, IN 46167 Submitted electronically: NCCIPTPMUE@cms.hhs.gov To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Jessica Cunningham, LAT, ATC

      Posted by Jessica Cunningham on 1/3/2020 12:16 PM

    • This "mutually exclusive" coding rule crosses disciplines as well. We were unable to bill ther act as part of an OT treatment yesterday because the PT billed for an evaluation.

      Posted by Joclyn Krevat on 1/3/2020 12:46 PM

    • The new CCI edits are detrimental to the high quality and hands on care that physical therapist perform on Medicare recipients daily. Such withholding of services will diminish the care Medicare recipients need and deserve.

      Posted by Chad Casey on 1/3/2020 1:43 PM

    • As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the edits described above. Thank you Karen Heckman, PT, MHS

      Posted by Karen Heckman -> DKU[<K on 1/3/2020 2:22 PM

    • 01/03/2020 Capitol Bridge, LLC National Correct Coding Initiative Contractor PO Box368 Pittsboro, IN 46167 Submitted electronically: NCCIPTPMUE@cms.hhs.gov To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Doni Dye PTA/DOR

      Posted by Doni Dye on 1/3/2020 2:23 PM

    • To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Chad Kuehl, DPT Physical Therapist -- Chad Kuehl, DPT 21st Century Rehab Boone Office: 515.236.9014

      Posted by Chad Kuehl on 1/3/2020 2:39 PM

    • As a PT I strive to provide the most appropriate care to each patient as possible and will not feel comfortable changing my practice patterns which have good outcomes. I am set in my ways and will most likely provide the tx if needed and consider it part of the eval. It seems to me that they know we will provide the tx anyway and are counting on us giving away our work for free. I.E: You are expected to do it for the patient but they don't want to pay for it. Its essentially a scam.

      Posted by Sara Detlor on 1/3/2020 2:44 PM

    • Guys- you can not spring this on us with no advanced notice! In addition, it is standard practice to begin care on date of evaluation. It better serves the patient and gets them the immediate care they deserve and require. Please reverse this ill advised decision and allow clinicians to begin care on date of evaluation. Thank you. Regards, Joe Redington, PT

      Posted by joseph redington on 1/3/2020 2:45 PM

    • This means Medicare is asking PT's to provide substandard care. An evaluation only without starting treatment the same day is poor care and unacceptable. I cannot tell a patient what is wrong with them and why, then tell them to come in next visit for a home exercise program, and interventions to help change their live for the better. We need APTA to confront this quality of care issue ASAP.

      Posted by Joe Flannery on 1/3/2020 2:46 PM

    • As a practicing physical therapist part of my evaluation process is educating and starting a patient on a program. This program relies heavily on a home program not only focusing on exercise but on establishing daily activities that focus on improving the patient's quality of life as well as achieving the patient goals. Treatment starts on the first day I see a patient. Often times patients are needing immediate help just as a doctor offers immediate help and direction in patient care a physical therapist must be able to provide services to a patient day one. Especially in the age of the opioid epidemic patients need critical education on activity and programming to reduce pain and return to function. Any delay by not being able to bill for critical care by a physical therapist increases a patient's risk of opioid dependence and prolongs their sessions with a physical therapist. Establishing a program and offering a patient a way to get better on the evaluation day creates trust and gets a patient on the road to recovery quicker.

      Posted by sarah jones on 1/3/2020 2:50 PM

    • This coding change will be detrimental to the treatment and progress for our patients. This goes against best practices for both occupational and physical therapists. Every time a patient comes through our doors they rightly expect to leave better than when they came in. That is the whole point of therapy, to gain independence and functioning within your environment. A patient can not make progress, gain independence and functioning through an evaluation. That happens with treatment. This prevents a patient from being treated at their first visit therefore prolonging their pain and lack of independence. This coding decision should be reversed for the benefit of all patients and to be in line with best practice for all disciplines. Sincerely, Erin Cobb

      Posted by Erin Cobb, OTR/L, CEO on 1/3/2020 3:34 PM

    • Therapeutic activity charges should be allowed as part of an evaluation and treatment provided by a licensed professional when these charges are an appropriate treatment plan component.I do not feel the CMS changes are appropriate.

      Posted by Donald G. Dixon, P.T. on 1/3/2020 3:36 PM

    • Yet another disappointing and arbitrary cut from CMS. Educating patients on proper TE/TA technique at the time of evaluation are crucial in the implementation of the plan of care. Patients are seeking our services to improve their function, and it is a disservice to them to not have access to the services that will be rendered. If patients are not able to receive meaningful instruction at the onset, they may have reduced compliance with the overall POC which could lead to diminished results.

      Posted by Kristen Jackson on 1/3/2020 3:58 PM

    • The eval/re-eval plus Ther Act is a critical issue and all should be submitting their letters to the address above. The article does not discuss it but the attached letter template does- the list of codes now considered mutually exclusive are COMMON PT procedures and in no way mutually exclusive (defined as Cannot be done in combination or not a possible treatment). Be sure to include that issue in your communications directly to NCCIPTPMUE@cms.hhs.gov

      Posted by Tara Manal -> =GYaBF on 1/3/2020 4:18 PM

    • This change drastically limits our ability as physical therapists to begin treating patients in the most effective way on day of initial evaluation. It places the patient at risk for a delay in their care which is detrimental to their overall plan of care and return to prior level of function. Delays starting from day one only mean more time spent in various facilities for that patient. It’s time to start placing the patient first and stop limiting our clinical judgement as therapists.

      Posted by Heather Green on 1/3/2020 7:49 PM

    • These new CMS NCCI edits are inappropriate, unneeded and restrict quality patient care. On days of evaluation/reassessment it is imperative that we as physical therapists are able to also treat the patient to capitalize on their found information, educate and initiate the healing process. This is not only necessary in the rehabilitation process but also to reduce continued compensatory patterns and make immense changes on the pain process. Those things taking place at initial evaluation/reassessment are absolutely necessary to give appropriate quality care to our patients. Please reverse this decision so the healing of these patients, so in need of this care, is not restricted buy this edit in coding.

      Posted by Thomas Herman,LPT on 1/3/2020 8:30 PM

    • Physical therapy is often the best conservative option for addressing pain, dizziness and disability. Frequently more economic in the long run, than surgery and medications. The evaluation process and the various time based codes, have very clearly defined content and purposes. These edits appear to be just another attack, in a long series of attacks, to eliminate the ability of the PT and PT companies, to be adequately compensated for their professional time, skill and knowledge. Think multiple procedure reductions, other CCI edits, sequestration..... This looks like another random effort at cutting costs, at the expense of patients and hard working professionals. This time there wasn't even the pretense of due diligence. No say at all for the professional community in this decision.

      Posted by Michael Wah on 1/3/2020 8:45 PM

    • Reversal is imperative for us Physical Therapist the autonomy to provide excellent and proficient care for the patient we serve.

      Posted by Connie Chiu, DPT. on 1/3/2020 10:03 PM

    • Me: After my initial assessment, I can assure you have a mechanical back strain and it can be resolved with some manual therapy and some gentle therapeutic exercise. Patient: That sounds great, I'm ready to get rid of this pain and stop taking meds. When can we start? Me: Schedule your next appointment at the front desk. My next available opening is in a week.

      Posted by jorge guerrero on 1/4/2020 10:03 AM

    • this is the message i get when i try to send the email to the above address: 'email address is no longer valid'.

      Posted by ac on 1/4/2020 10:04 AM

    • As a PT, I find this news to be devastating! What a disservice to the patients, especially those who are post surgical. It is imperative to restore mobility as soon as possible in post surgical patients which is initiated during the initial evaluation and carried through by a HEP. What a disservice to the patients as well as to the professions of PT and OT. Please reconsider your decision and the impact that it will have on some many people.

      Posted by Pamela Rhone on 1/4/2020 10:44 AM

    • While these changes are concerning with regard to patient care and our profession, they are not surprising or unexpected. While I do not know exactly how these changes materialized, I do know that most reimbursement changes such as this are a result of non-compliance with the use of the codes. I have seen this happen in the past. Many rehabilitation facilities including private practice, corporate, and hospital-based, have productivity requirements. Many expect therapists to average 4 units of service per patient. The evaluation code is also not given more weight than the other codes even though it is untimed. I have been told by previous supervisors (all of which were licensed therapists) to charge 97140 for passive joint mobility assessment portion of an examination as it was "manual" in nature. I have also been told that evaluating a patient's body mechanics during an evaluation warrants use of the 97530 code. These were the facilities' ways of increasing reimbursement rather than providing appropriate compliant care. When refusing to follow suit and explaining that this was non-compliant unbundling of the eval code, I was told the practice can't make money without doing it, or I was reprimanded, or I was let go. One employer chose to change they way I was paid so my pay was a minority percentage of the amount of reimbursement the practice received for my care. This pressure to be non-compliant drove me out of private and corporate practice. This suggests that our profession has no one to blame but itself for these changes. I surmise that the majority of readers of this post and APTA articles are association members aware of the direction we are trying to go and the issues that are negatively affecting our progress to get there. Association members, however, are the minority of therapists in practice. If APTA membership is less than 40%, then 60% are unaware, uninformed, or just unconcerned with what is happening. Subsequently, there is an overall lack of concern for compliance in the community. Increased internal policing of the profession with regard to compliant billing practices must occur if we expect these changes to be reversed and avoided in the future. I would also challenge all therapists to evaluate your own evaluation process. If you have time to compliantly charge a patient for 1 or 2 units of timed care after your examination, I would ask how much time you are spending on your examination. Are you examining the patient at a wholistic level or are you evaluating just a body part? Are you finding the source of the patient's problem or are you just measuring their diagnosis? The fact that the biggest risk factor for a physical injury is the history of a previous injury suggests that we are not fully rehabilitating our patients. Full rehabilitation begins with a thorough evaluation. Spend the time to fully examine your patients rather than rushing into treatment to bill codes. Our highest paid code is the evaluation code. Our highest skilled code is the evaluation code. There are reasons for this. Think patient before payment. Respectfully submitted.

      Posted by James Love on 1/4/2020 11:16 AM

    • Why do you have to keep messing with things that really is working in healthcare!! Physical therapy is the best alternative for conservative care not medication or surgeries!! Cut reimbursements on surgeries which are unnecessary 80% of times!!!

      Posted by Mehul on 1/4/2020 1:25 PM

    • This needs to change. I hope people come together to make it happen.

      Posted by Joyce Reader on 1/4/2020 1:52 PM

    • I disagree with the restrictions that are being imposed on PTs and jeopardize quality of care and patient's safety. On the first visit we not only evaluate but treat which includes correcting posture, adjusting equipment instruct on appropriate functional activities. Especially when it is a postsurgical orthopedic case. Thank you, Ksio Murdakhayeva , DPT

      Posted by ksio murdakhayeva on 1/4/2020 7:19 PM

    • How is restricting the way we will treat and therefore bill adding to patient care?

      Posted by Kinnari Ashar on 1/4/2020 9:24 PM

    • A sample letter for patients: Dear Patients We really care about you! Please bear with us as we deal with a new Medicare/Insurance change that was announced on 1/2/20, retroactive to 1/1/20. We will no longer be reimbursed for Treatment or Education for your condition on the same day as your Evaluation. Please understand that providers had no input in this decision. You will now need to have 2 initial visits to receive customary/standard care. This may include 2 copays and will use 2 of your insurance allowed visits. This is just another way that insurance companies are working to prevent access to care. Please understand that we are scrambling to conform to this new insurance algorithm. Please email: NCCIPTPMUE@cms.hhs.gov with your complaints. Thank you, Erin and Ian *All private insurance companies follow Medicare guidelines. This is a nightmare for providers who work with children, athletes, pre/post operative seniors, workers, just about anybody who needs to learn/modify activities.

      Posted by Erin Rodriguez on 1/4/2020 9:25 PM

    • Please remove our uninformed lobbyists or at least give APTA leadership and lobbyists a 17% decrease. It is unacceptable to be caught off guard like this and constantly be begging and making a case to get our profession back.

      Posted by Mike Holway on 1/5/2020 12:05 AM

    • I am a PTA and agree with the above comments. As a PTA I will most likely treat the patient on the second visit. I expect patient education, safety, and home exercise program to be established on first visit; all therapeutic activities. PAIN is addressed every visit with the most beneficial treatment from manual therapy whether it be soft tissue, PROM/AAROM , joint oscillations or joint mobilization, PNF etc. If the patients main complaint is pain and loss of function there should be no limitations to what can be included in the initial evaluation especially those with co-morbidities, mental illnesses, disabilities. And what about evaluating a patient post op Ortho with ROM protocol to follow...the most important in this stage of healing. Non clinical people should not be making these decisions for patient care is lost . It’s very sad to see what healthcare is becoming.

      Posted by Rachelle Lombardo on 1/5/2020 12:20 AM

    • 1/5/2020 Capitol Bridge, LLC National Correct Coding Initiative Contractor PO Box 368 Pittsboro, IN 46167 Submitted electronically: NCCIPTPMUE@cms.hhs.gov To Whom It May Concern: As a member of the American Physical Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Physical therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Physical Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard physical therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Physical therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, Derek Xie, PT, DPT Physical Therapist

      Posted by Derek Xie on 1/5/2020 9:51 PM

    • Manual therapy and therapeutic activity charges should be allowed as part of an evaluation and treatment provided by a licensed professional when these charges are an appropriate treatment plan component and should not require any other type of modifier. I do not feel the CMS changes are appropriate.

      Posted by Elnathan Eldredge, DPT on 1/6/2020 9:53 AM

    • To eliminate the therapists ability to administer care directly following evaluation is not only ineffective medical care it is cruel to our patients to force them to wait for another session to begin to treat their ailments. Tying the therapists hands to help a patient quickly and efficiently is the worse kind of administrative interference. Please revoke this new directive.

      Posted by Supriya Maniar on 1/6/2020 2:26 PM

    • Typical. No respect for our profession. Our pay is completely dictated by insurance companies and the APTA does little to strengthen our dying profession. Were required to spend nearly $200k and seven years of schooling to get the credentialing needed to practice PT, but just keep chipping away at our livelihood and leave us barely unable to pay for our student loans. What a joke. We need better leadership.

      Posted by Thomas Fraind on 1/6/2020 2:55 PM

    • 1/6/2020 Capitol Bridge, LLC National Correct Coding Initiative Contractor PO Box 368 Pittsboro, IN 46167 Submitted electronically: NCCIPTPMUE@cms.hhs.gov To Whom It May Concern: I am a certified lymphedema therapist and work in my own practice in Bloomfield, NJ. These changes are devastating for my population of the patient that are waiting weeks for this appointment. Lymphedema is a specialty that is not easy to come by. When the patient finally get a credentialed therapist they want to know what they can do. With these new changes, it is very difficult to educate my patients on what they can do in order to improve this debilitating condition. Some of my patients come in with leaking lymphatic conditions. The new changes make it so difficult to start treatment immediately. To those involved with making these drastic changes, I hope that your parents don't require this specialty and have to wait for a full treatment. This is absurd and as a member of the APTA, I seriously hope that communications are engaged to reverse this terrible decision. I am passing this onto my patients so they can see how decisions are being made for them without their best interest in their health. Ana Pozzoli PT-CLT-LANA

      Posted by Ana Pozzoli on 1/6/2020 5:00 PM

    • I feel that is a disservice to our patients to not have access to the services provided. Patients may not have good compliance if they are not properly instructed at onset.

      Posted by Jennifer Morrison PTA on 1/6/2020 7:09 PM

    • Is this Medicare part B only? Or also A? And Medicaid?

      Posted by Julie Fulton on 1/7/2020 9:53 AM

    • As therapists, we want to provide the best possible care to our patients, but it seems more and more therapists are being made to do more but provide patients with less: time and effort. Please open up communication and allow therapist to speak and stand up for what is best for their patients and time being provided!

      Posted by B. Fannin on 1/7/2020 11:31 AM

    • The most important thing in the medical field is making sure patients receive the best care they can in a convenient and effective (timely) manner. This new coding implicates and restricts that, which means it is preventing patients from receiving the best quality of care. We advise the NCCI to reverse this new coding decision.

      Posted by William Cintron on 1/7/2020 2:18 PM

    • On the day of initial evaluation, it is imperative that our patients receive education about how to alter their daily activities to make them more efficient, less painful, and more independent. Not being able to provide this service to our patients the first day is a disservice to them and decreasing the worth of physical therapy and occupational therapy as a whole. When it takes some patients several weeks to get in for a return visit, it is absolutely wrong to deny them the ability to learn these things on the first day. I strongly believe that these changes should be reversed for the health, safety, and wellness of our patients and loved ones. Sincerely, Elizabeth Sitterley, PT, DPT

      Posted by Elizabeth Sitterley, PT, DPT on 1/7/2020 6:22 PM

    • I am writing in concern of how this shift in reimbursement will change practice. Providing education about the patients anatomy, movement, and their current dysfunction as well as educating them on simple behavioral modifications and changes in movement they can make to improve their symptoms needs to occur at initial evaluation and falls under the coding of Therapeutic Activity. If these codes are not reimbursed together during 1 visit this will result in reduced quality of care, therapists providing care and not being paid for their services resulting in therapists going out of business or the expectation to see more patients in a shorter time to stay afloat, or will guide therapist to be forced to use an inaccurate code perpetuating the underlying issue in the 1st place. I support this reversal of this change. Therapeutic Activity provided PTs a way to give patients their life back by giving the power to the patient through education and lasting change in movement. Yes, changes need to be made, but this will only result in bigger issue sending us down the volume, not value path. Thank you for listening.

      Posted by Taylor on 1/7/2020 6:25 PM

    • I’ve been in this field for over 32 years. All the changes that have been made over the years are never in favor of better patient care. They are forcing quality of care to decrease. We should be providing the care the patient needs and not have that dictated by anyone other than the evaluating therapist.

      Posted by Ellen Juzba on 1/7/2020 7:56 PM

    • I am the director of Outpatient orthopedic based PT practice - A very busy practice . I feel this is a disgrace to our PT practice , as we are suppose to inform our patients on Eval day about PT pros and cons and precautions and restrictions . Patients these days have tons of questions about their prognosis related to their injuries and surgeries. I request that PT and OT should be given the privilege to make proper decisions towards the their patients goals and target dates . This can only happen if Medicare cooperates .

      Posted by Vikas Suri PT on 1/7/2020 8:47 PM

    • To Whom It May Concern: As a member of the American Occupational Therapy Association, I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Occupational therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While occupational therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Occupational therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession’s vision of transforming society by optimizing movement to improve the human experience. CMS developed the NCCI to prevent inappropriate payment of services that should not be reported together. One function of NCCI PTP edits is to prevent payment for codes that report overlapping services except in those instances where the services are separate and distinct. Occupational therapists currently are challenged in the appropriate delivery of care by three existing problematic edits. The American Occupational Therapy Association has requested reconsideration of these edits in order to ensure that patients are able to receive necessary services during a single treatment session. 97530 97116 Mutually Exclusive 97530 97113 Mutually Exclusive 97140 97530 Mutually Exclusive In addition to the above edits, the January 1, 2020, NCCI PTP edit file includes new edits that will further limit appropriate care and are inconsistent with the edit model: CPT codes 97150 and 97530 are now listed as a column one code with all of the physical therapy and occupational therapy evaluation and reevaluation codes (97161-97168) and are not permitted to be billed on the same day as a physical or occupational therapy evaluation. Additionally, there is a new edit requiring a modifier 59 for CPT 97140 when billed with a physical therapy or occupational therapy evaluation. The above edits conflict with current CMS policy. As stated in Chapter 15 of the Medicare Benefit Policy Manual, “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits. It is appropriate that treatment begins when a plan is established.” Standard occupational therapist practice includes the initiation of care on the same day as an evaluation and the provision of care on the same day as a reevaluation whenever possible. Occupational therapists identify the issues or conditions requiring treatment during the examination/evaluation and work to implement treatment at the same time. Given the very limited number of occupational therapy sessions available to a patient, each visit with a occupational therapist must be maximized to ensure that the patient has the best opportunity for recovery. Patients who present with pain, fall risk, mobility issues, challenges performing activities of daily living, or the inability to execute their employment-related tasks require immediate intervention. Any delays in care can negatively impact the ultimate outcome of care. The edits identified in the new edit tables restrict access to care and ultimately reduce the opportunity for patients to achieve the best outcomes. What’s more, there is no indication from CMS, practitioners, or patients that the absence of these edits has led to the misappropriation of care and/or undue reimbursement. I have significant concerns that the new edits fail to align with the current practice of care and will cause undue hardship on Medicare providers and beneficiaries. In an effort to limit the administrative and financial burden on Medicare beneficiaries as well as on Medicare providers, and to better support the effective and efficient treatment of a patient’s condition, avoid delay of a meaningful intervention, and prevent the need for an otherwise unnecessary follow-up visit, I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits described above. Sincerely, -Vickie Towne OTR/L

      Posted by Vickie Towne on 1/8/2020 7:03 AM

    • I may be reading this incorrectly, but to me, it appears that therapists are still okay to charge CPT code 97110, which is an individual TP charge, with an evaluation. The 97150 reads as a group charge, which my clinic never uses because we do strictly one on one therapy.

      Posted by Hannah on 1/8/2020 12:01 PM

    • I feel that this is a horrible idea! How are we supposed to help our patients with rules like this?

      Posted by Tiffany Lenhart on 1/8/2020 12:53 PM

    • I got an error message when I emailed the address provided...I copy and pasted it, so it wasn't a typo. Has anyone else had this problem?

      Posted by Meredith L on 1/8/2020 1:07 PM

    • This is limiting the way we can treat our patients and be fairly reimbursed for what we do. Especially in the inpatient setting. Patients that need to have bed mobility or transfer training as a second visit in the day ( if evaluated earlier) are not being reimbursed. At least give us the option of having the ability to apply a mod 59 to distinguish that is separate and distinct. This is not in the patients best interest

      Posted by Pamela Randolph on 1/8/2020 2:09 PM

    • Therapeutic Activities is an essential tool in regards to the education included in an initial Evaluation. As a PTA the education, explanation of goal planning, and initial implication of a Home Exercise Program during the evaluation process is essential to insuring the progress of a resident/patient. Setting the ground work for what is expected from our patients, and what they can expect from us is vital to the therapeutic process.

      Posted by Timothy Kasperitis PTA on 1/8/2020 4:57 PM

    • As owner and President of Mesisca Physical Therapy in Southern California I’m stunned by such a lack of common sense in the decision to eliminate 97530 billing on the day of evaluation. The number one reason for physical therapy is to improve a patient’s function. Functional outcome is the key. MC has established rules and encouraged functional tools to prove Functional outcome. How is it possible that we’re removing the greatest tool in the physical therapy toolbox, on the first visit and calling it reasonable. And secondly how in the world was this unreasonable, thoughtless, blindsiding and “anti-patient care decision” done without the APTA respectfully getting advanced word of it. Who is in charge of dropping such a sneaky, non-well thought out billing limitation ?? Please be reasonable and consider reversing this decision in the name of “PATIENT” care. That is the reason this profession exists. “PATIENT” care! Not “tricky billing care” !! Simply put, there is no reasonable clinical rational why these codes should not be billed on the same day. This poor decision prevents patients from receiving the best care possible. This is equivalent to removing the wrench or screwdriver from a mechanics toolbox. Why are we limiting our ability to best treat a patient??? “PATIENT” care is our goal. We are an educated society. Why are we making such foolish decisions?? Foolish decisions have bad outcomes. Please let us be WISE, and reverse this detrimental restriction of billing 97530 on the initial evaluation. Let us please get back to “PATIENT” care.

      Posted by John Mesisca on 1/8/2020 5:10 PM

    • I am writing to express my deep concern regarding proposed NCCI PTP edits that become effective January 1, 2020. Physical therapists play a unique role in prevention, wellness, fitness, health promotion, and management of disease and disability. Physical therapists have the expertise and the opportunity to help individuals improve overall health and prevent the need for avoidable health care services. Physical therapists’ roles may include education, direct intervention, research, advocacy, and collaborative consultation. Given the very limited number of physical therapy sessions available to a patient, each visit with a physical therapist must be maximized to ensure that the patient has the best opportunity for recovery. The proposed NCCI PTP edits will be limiting the way we can treat our patients, reduce the opportunity for patients to achieve the best outcomes, and reimbursement for what we do. I strongly recommend that Capitol Bridge, LLC and CMS remove the proposed edits.

      Posted by Nicolina Pentrelli Deraco on 1/8/2020 6:32 PM

    • I agree with all the above comments. How is this justified? Our treatments are supposed to improve a patient's function yet we can't start that until the second visit? This does a huge disservice to all clients and our health care system. These edits need to be modified or removed for optimal, efficient and effective patient centered care.

      Posted by Britni on 1/9/2020 9:44 AM

    • I am a Physical Therapist in private practice. On the first visit, following evaluation and determination of the patients primary need, it is imperative, from my perspective , to begin patient education and training in ADL activities. It is on the first visit that it is most effective to begin therapeutic activities to enable the patient to immediately begin their rehab process. It makes no sense whatsoever to delay implementation of therapeutic activity since it offers the patient an understanding of their condition, and the ability to participate in the healing process in their life activities.

      Posted by Susan Henning on 1/9/2020 1:56 PM

    • If I am evaluating a low level person and all they can tolerate is rolling, supine>sit edge of bed, and possibly sit>stand what else possibly am I to charge besides functional training. These patients need to be able to roll and functionally move to be able to have their brief changed and potentially assist with dressing in bed.

      Posted by Jill on 1/9/2020 5:54 PM

    • CMS is going to cost-cut their way into spending more money on worse problems because they will not allow therapists to DO THEIR JOB. Like the old Fram Oil Filter commercials said: "You can pay me now, or pay me later." Later in this case is going to really hit hard for the patient's needing the care and for our society paying the bills. Reverse this decision.

      Posted by Stab Stanhope on 1/10/2020 10:30 AM

    • I just checked the spreadsheet at https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/NCCI-Coding-Edits and it showed that 97530 is allowed with 97164. Anybody else reading it that way?

      Posted by Ron Cole PT on 1/10/2020 11:14 AM

    • It is interesting CMS's focus is on function and then they place this barrier in the way. On the initial visit, functional codes are used often to help someone learn new habits with movement, sitting, sleep position, and transferring to help reduce re-aggravating factors. It is an essential code to have access. This is just common sense. It would be nice the CMS staff or who ever is behind this, would just stop and think what the patient's needs are. You guys pay for so many worthless interventions which have PAC $ behind them and you make life even harder on our profession to provide the most empowering help in the medical field. We help people become independent and self-reliant - maybe that is the problem - maybe we're getting too good at really helping patients and so let pay us less and make it harder to treat so we are less effective. The drug companies would certainly like us to be out of the way. We are cutting into their profits,; ok now it make sense!

      Posted by vince Hanneken on 1/10/2020 3:39 PM

    • I am writing in regards to the new code changes that cannot be used on evaluation as of 1/1/2020. As a PT, our job is to assist and educate each patient in order to improve their mobility and safety and help them become more independent. On the initial evaluation, that is a large part of our actions. It is not only assessment of that individual to document in the eval. It is assisting them rolling in bed, getting to edge of bed, transferring to chair/WC, and many times transferring to toilet and educating them in proper body mechanics during transitional movements. And these actions can be necessary several times during the session. How can that not be charged as functional activity? Whoever is in charge of this change must not be working with real live patients and only looking at numbers to crunch. Please strongly consider reversing this code change and let us do our jobs effectively.

      Posted by Carolyn Bailey on 1/11/2020 9:45 AM

    • Why does Billing have to be so complicated. I had a question on modifier 59 for eight years I tried to contact CMS and Medicaid at the state level nobody could give me an answer. My senator gave me his seat on a medical advisory Council still no answers. especially when working with outpatient pediatrics, medicaid billing systems try to stick the square pegs and round holes. I’m not sure of the insurance world understands the real definition of a separate and distinct service. And I agree with everything stated above during evaluation it is best practice to treat the client and address key problems. Please consider the viewpoints of the therapist revoke this edit and let us be effective therapist!

      Posted by Catherine Risigo Wickline on 1/13/2020 2:00 AM

    • This new coding restricts the ability of physical therapists to provide effective care in a timely manner. These changes should be reversed.

      Posted by Liz Carlton on 1/13/2020 5:10 PM

    • I am a practicing Physical Therapist in a hospital setting. I am appalled at the new code changes and the limits that CMS has put on us as professionals! Making a profit in a hospital through inpatient services is not even possible, so what we code is real relating to our treatments. Medicare/ Insurance Companies are already imposing limits on a patient's length of stay in the hospital in spite of what the Doctor may think is warranted. So now, Medicare says that we can't begin teaching the necessary strategies to make our patient safe the day of evaluation and possibly shorten their stay? We see many back surgeries who go home the day of the evaluation, so now they must stay 1 extra day in order to get the proper mobility training they need to ensure a successful surgery, to be safe at home and hopefully prevent a return visit? Or when we evaluate our total joints on the same day with a goal of going home the next day, we can't educate them either on how to successfully mobilize in a safe manner (without dislocating their hip!) until day 2, which is their discharge day? This is so conflicting: get the patient out early, but you can't do what is necessary to get them out in a reasonable amount of time? See how ridiculous this is? This not only will increase the cost by delaying treatment, but more importantly, it puts the patient at risk by not educating them in safe mobility skills in a timely manner. Respectively submitted,

      Posted by Deborah Lambert on 1/13/2020 10:17 PM

    • It's hard to find a lot of details about this. Does it apply to Med A AND B??? Just outpatient? Managed Medicare? Any restriction is ridiculous, but would like to minimize the damage if it only applies to certain insurance populations.

      Posted by Angela Curtis -> >OQaCK on 1/14/2020 3:04 PM

    • @Angela: The NCCI PTP edits apply to Medicare FFS outpatient settings, however, many Medicaid programs and the majority of private insurers follow them as well. Workers comp and self-insured plans may develop their own edits. We encourage providers to check each of their payer’s policies. See page 5 of the CMS NCCI MLN matters booklet for who the edits apply to under Medicare: https://www.cms.gov/media/125221#page166

      Posted by APTA staff on 1/15/2020 7:06 AM

    • This change is not benefiting the patients and their care when we as therapist are to treat per patient's needs how are we to do that when they are telling us what we can and can't bill when an evaluating therapist evals.

      Posted by Michelle Bowman COTA/L on 1/15/2020 11:45 AM

    • Our focus as healthcare providers in the hospital setting is making sure our patients receive the best care they can in a timely manner. It may have been intended for outpatient, but those patients in observation status in the hospital would fall under this guideline as well. Many of these patients need further treatment in order for facilitate a safe discharge home. This new coding implicates and restricts that, which means it is preventing patients from receiving the best quality of care. We respectfully advise the NCCI to reverse this new coding decision. The current status is not what is best for patients.

      Posted by Erine Cala on 1/15/2020 4:18 PM

    • This will likely delay recovery time and increase dysfunction. Please reconsider.

      Posted by garett clayton on 1/17/2020 10:49 AM

    • After 24 yrs as a practicing Physical Therapist I have come to know that CMS is constantly investigating, innovating and imposing new regulations on reimbursement issues to providers all for the sake of saving $$. I’m sure you’ve heard of the saying, “ get the best Bang for your Buck,” this means the Best Value for the Price! Why not allow the degreed, experienced, professional clinician whom exercises the best clinical judgement in their respective practice to determine what is in the Best interest of the Patient? Allow us to Bill in combination with our initial evaluation, CPT codes (97530) Therapeutic Activities and/or (97150) therapeutic procedures to begin the patients rehabilitation and recovery ASAP. The sooner we address these impairments, the sooner the recovery! We might just save CMS some $$ in the end with a quicker discharge from services! That’s something to think about!!!

      Posted by Richard Jensen, PT on 1/21/2020 12:03 PM

    • This email address keeps kicking back to me as invalid. Is there an updated email to which we can send these signed letters? Thanks

      Posted by Gillian kania on 1/22/2020 11:00 AM

    • Being a new owner of a physical therapy practice really makes me wonder if that the system “insurance providers” really want the best for the patient. There is something wrong with not allowing what PTs have learned and want to teach to help with faster recovery times. It really comes down to making a buck instead of allowing what is learned to be used to aide in the recovery of our patients. Same on this system.

      Posted by Victor Rusenescu on 1/22/2020 11:28 AM

    • This change is not benefiting the patient nor is it practical in the outpatient setting. When evaluating or re-evaluating (OT or PT) it is necessary as well as appropriate to "reassess" the patient's status and then continue with therapeutic activities 97530 for the remainder of the patient's visit. This new way of billing will only lead to additional costs to the patient, and the therapist will no longer be able to educate or introduce plan of treat on that same day.

      Posted by Lana Broome on 2/5/2020 6:50 PM

    • CMS has rescinded the NCCI therapy PTP edits:NCCI update Therapy PTP edits https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd

      Posted by Sue Roehl on 3/6/2020 11:12 AM

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