Skip to main content

Within the final rule of the 2025 Medicare Physician Fee Schedule, CMS established a welcome exception to the plan of care, or POC, signature requirement for initial certification. Applicable to claims with dates of service on or after Jan. 1, 2025, when a patient is referred for physical therapy from a physician or other qualified nonphysician practitioner, this new exception allows a signed and dated order or referral to meet the certification requirements as long as the order is in the patient’s medical record and there is evidence that the plan of care was submitted to the referring provider within 30 days of the initial evaluation.

Previously, in addition to submitting the POC to the referring provider within 30 days of initial treatment, the PT was required to have the provider return a signed and dated copy of the PoC as evidence of certification. This meant following up with physicians for signatures, often submitting multiple requests for, and confirming the existence of, the provider's signature on the plan of care in order to be paid for Medicare Part B outpatient therapy services. In effect, claims that otherwise met medical necessity requirements may not have been paid for lack of a timely physician signature.

Under the new exception, once the PT has transmitted the POC, the onus now is on the referring provider to either return the signature or indicate changes; absent either action, silence serves as ascent to the PT's submitted POC. In effect, the new rule places increased emphasis and trust on the PT's clinical judgment, requiring only documentation evidencing the order or referral.

Citations: 42 CFR Part 424, Subpart B; 89 Fed. Reg. 97710, 97912-97918; Medicare Benefit Policy Manual, Ch. 15, Sec. 220.1.3, 220.3.

Log in or create a free account to keep reading.


Join APTA to get unlimited access to content.


You Might Also Like...

News

APTA State Chapters Fuel Legislative Wins in 2025

Aug 6, 2025

As the 2025 legislative season has come to a close in most states, many APTA chapters achieved significant victories that improve payment, address provider

Article

Exciting Volunteer Opportunities Open Through Aug. 31

Aug 4, 2025

APTA is powered by members who step up, speak out, and drive the profession forward. Volunteering is not only a chance to influence the future of physical

News

APTA's Ongoing Advocacy on Payment Reform

Aug 4, 2025

Patients and providers are frustrated and angry. A broken Medicare system has failed to deliver high-quality care and provide needed payment levels so