Novitas Solutions, a Medicare Administrative Contractor, has amended its FAQ section on outpatient rehabilitation to align with the plan of care signature exception from the Medicare Physician Fee Schedule rule that went into effect Jan. 1, 2025. The updates were made after APTA and the American Occupational Therapy Association sent Novitas a letter of recommendations that identified omissions in the FAQs and urged for more accurate guidance.

Providers rely on MAC FAQs, guidance, and other educational resources to ensure compliance with Medicare regulations. Novitas is one of the largest MACs, underscoring how important it is that their guidance conveys correct information to providers in its jurisdiction. Thanks to APTA and AOTA, the updated FAQ clarifies that when a patient is referred for therapy, providers can meet certification requirements by simply ensuring that a signed and dated order is documented in the patient's medical record and that there is evidence that the plan of care was submitted to the referring provider within 30 days of the initial evaluation. This policy change significantly eases the administrative burden on therapists and increases patient access to care.

APTA continues to advocate to ensure content provided by the Centers for Medicare & Medicaid Services and Medicare Administrative Contractors reflects the latest regulatory changes set forth in the 2025 fee schedule rule. This advocacy work highlights the importance of clear communication and support for therapy professionals as they navigate regulatory requirements while focusing on delivering high-quality patient care.

If you are aware of a MAC with incorrect guidance or education on the plan of care exception, please contact advocacy@apta.org.