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The final 2023 Medicare Physician Fee Schedule contained some good news around supervision in the use of remote therapeutic monitoring by PTAs by allowing less-burdensome general supervision of PTAs in rehab agencies, comprehensive outpatient rehab facilities, and other institutional providers of physical therapy. However, due to some inconsistencies in the rule, private practices were left hanging: Do they continue to provide direct supervision in these instances, or can they too move to general supervision?

APTA asked CMS that question, and the agency responded directly to the association. The answer: Private practice settings should continue direct supervision of PTAs providing RTM, citing a section of the rule requiring direct supervision of PTAs in private practice settings across activities. That clarification is consistent with APTA's initial advice that providers in this setting take a conservative approach until the regulatory fog lifted.

The provision cited by CMS is the target of ongoing APTA advocacy efforts. APTA supports a move to general supervision in outpatient practice under Medicare for all activities, and advocated for federal legislation to do just that. Ultimately, that legislation wasn't acted upon in the previous Congress, but the association is pressing for the issue to be taken up in the recently seated 118th Congress.

Need to learn more about RTM coding issues? Check out the APTA Practice Advisory on the use of remote therapeutic monitoring codes under Medicare.


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