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.

Note: As of August 2026, CMS has not updated Chapter 15 of the Medicare Benefit Policy Manual to reflect the exception to the plan of care certification requirement. Until the manual is updated, members should refer to the MLN Fact Sheet, Complying with Outpatient Rehabilitation Therapy Documentation Requirements.

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.