MPFS proposed rule: New therapy modifiers to report reduced payment for PTAs, OTAs

CMS is proposing to create two new modifiers for reporting physical therapy (PT) and occupational therapy (OT) services performed in whole or in part by PT assistants (PTA) and OT assistants (OTA).

The modifiers are included in the 2019 Medicare Physician Fee Schedule (MPFS) proposed rule and would go into effect for services provided on or after January 1, 2020. If the modifiers are finalized, CMS plans to allow voluntary reporting during 2019 to test its systems prior to implementation.

The new modifiers are being proposed to allow CMS to implement a payment reduction for these services as required by Section 53107 of the Bipartisan Budget Act of 2018. Starting January 1, 2022, payment for services provided in whole or part by PTAs and OTAs will be made at 85% of the standard Part B payment amount. Although voluntary reporting would begin in 2019 and mandatory reporting in 2020, the payment reduction would not be applied until 2022.

There are currently three modifiers used for reporting therapy services, -GP, -GO, and -GN. The new modifiers would be added in addition to the three existing therapy modifiers. Currently, claims for therapy services performed in whole or in part by PTAs or OTAs are reported using modifier -GP or -GO respectively. If the proposed rule goes into effect, those services would be reported with either of the two new modifiers. In addition, CMS would edit the descriptions of modifiers -GP and -GO to specify to which professionals (i.e., physician, therapist) they apply.

CMS notes that the new modifiers and the associated payment reduction would not apply if a PTA or OTA performed administrative tasks. The new modifiers would be used only for therapeutic services. CMS also reminds providers that PTAs and OTAs cannot report services incident to a physician, therapist, or non-physician practitioner.

The proposed rule will be published in the Federal Register July 27. Comments on the proposed rule will be accepted until 5 p. m. on September 10. All comments should reference file code CMS-1693-P. Comments are be submitted electronically on regulations.gov or via regular or express mail sent to CMS, attention: CMS-1693-P.