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Five Takeaways from the 2020 Final Rule

The CY 2020 Medicare Physician Fee Schedule Final Rule recently came out. As usual, reading – and deciphering — it is not for the faint of heart. However, our fearless team hunkered down and delved into the details. Here are five takeaways from the final rule:

  1. It’s not all doom and gloom when it comes to using physical therapy assistants (PTAs) and occupational therapy assistants (OTAs): CMS made some positive changes around how assistant modifiers will be applied to therapy services delivered “in part” by a PTA or OTA starting in 2020. These new modifiers will effect reimbursement in 2022.
  2. The devil is in the details when it comes to using PTAs and OTAs. The new assistant modifiers present additional complexities around claim processing that we all need to understand and take heed of in 2020.
  3. CMS hasn’t backed down on the proposal to cut payment for physical therapy providers by 8% in 2021: CMS still plans to go ahead with proposed E/M code changes, although they have not yet determined how codes will be revalued. Unless the powers that be change their minds, this could mean a frightening 8 percent reduction in Medicare payments for therapists in 2021. The APTA will be advocating for us heavily in the upcoming year to reconsider proposed changes. The bottom line—we all must band together to help prevent this ill-conceived proposal from becoming a reality.
  4. MIPS is not going away. It’s expanding. Contrary to popular belief (and folklore), MIPS isn’t going away in 2020. Rather, taking part is becoming even more critical as the performance threshold increases from 30 in 2019 to 45 in 2020 and the exceptional bonus threshold increases from 75 points to 85 points in 2020. Our takeaway on this? Stay ahead of the game and opt in to participate now before you are forced to play serious catch up in the coming years. Additionally, there are stricter implications coming in 2020 for eligible providers who choose not to opt in. Decide to sit on the sidelines again and you risk a 9 percent penalty (compared to 7 percent in 2019). Learn other reasons you should participate in MIPS with this blog from our sister company, Keet Health.
  5. There’s a hodgepodge of other changes too. Included in the 2475 pages of the final rule are some other updates worth noting:
  • The KX modifier threshold amount will rise from $2,040 to $2,080 for physical therapy and speech-language pathology services combined, and by the same amount for occupational therapy services. The targeted medical review threshold stays the same at $3,000.
  • Two dry needling codes have been added but they will remain uncovered (unpaid) unless specified by a national coverage determination. If the codes were covered, CMS has taken the stand that they should be considered as “sometimes therapy” procedures rather than “always therapy. The CPT codes for dry needling:
    • 20560: Needle insertion(s) without injection(s), 1 or 2 muscle(s)
    • 20561: Needle insertion(s) without injection(s), 3 or more muscle(s)

Have questions or want more details? We’re hosting a webinar with compliance expert Nancy Beckley on December 5th, 2019 to help decipher the myriad of Medicare changes and their potential impact on your practice. Register here.

The information provided herein is intended to be general in nature. It is not offered as legal or insurance related advice, and is not a complete description, or meant, or intended, to replace or be interpreted as specific, of Medicare requirements. Although every effort has been made to ensure the content herein is correct, we assume no responsibility for its accuracy. Contact Department of Health & Human Services (DHHS) Centers for Medicare and Medicaid Services (CMS) for more information.

4 thoughts on “Five Takeaways from the 2020 Final Rule

  1. In the last Webinar for the Proposed Rule for 2020 the mention under the Summary that the KX modifier threshold formerly know as the Therapy Cap for PT/ST stayed the same at $2080.00 combined and OT $2080.00. The mention of the Target Medical Review Threshold in the print our from the Blog indicated was increased from $3000.00 to $3700.00. Above it is mentioned the Targed MR stays the same at $3000.00. Can you tell me which is correct?

    • Hi Pam, thanks for your post. The Target Medical Review will stay the same at $3,000. The $3,700 figure you cited is from an older blog post that was written prior to the release of the final rule.

  2. Another question pertaining to therapy under Home Health Agencies beginning 2020. Our understanding for Home Health Agencies in 2020 is the case reimbursement for HHA will include all services that a patient needs under that same case reimbursement. Currently our understanding is services for PT/OT or ST are not included in the case and could be billed separatly for additional reimbursement. Is this information correct? Also, is the Plan that a HHA establishes for a patient being reduced from 60 days to 30 days for 2020?

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