With PTs and PTAs now 15 months into a new Medicare rule requiring the use of a coding modifier when services are furnished "in whole or in part" by a PTA, the U.S. Centers for Medicare & Medicaid Services recently provided more guidance around exactly how those modifiers are supposed to be used — and APTA has adjusted its member resources accordingly.
CMS has provided additional details on the policy for calculating the 10% "de minimis standard" and a set of billing examples that illustrate how the CQ modifier should be applied to indicate services provided by a PTA.
The new modifiers don't affect payment now, but they will trigger payment at 85% of the applicable fee schedule rate beginning in 2022. APTA and other organizations have opposed the payment differential, which is required by law. APTA also voiced concerns about a general lack of guidance around exactly how clinicians should use the modifiers.
To help members prepare for the change, the association created a Quick Guide To Using the PTA Modifier, which has been updated to reflect the new guidance from CMS. Like the CMS resource, the guide contains examples, and includes a handy reference chart and tips on documentation.
But that's not all APTA has to offer to help members understand both the application and background of the rule. Here are two other resources that can help fill in the gaps.
How To Apply the New CQ Modifier
This Compliance Matters article from the March issue of APTA Magazine provides a brief background of the rule before diving into just how it is applied. It also includes more scenarios to help readers get a sense of how the rule works in the real world of therapy.
The PTA Differential: How We Got Here, and What's Next
This perspective from early 2020 lays out the entire history of the differential, from its first mention in the 2018 Bipartisan Budget Act to APTA's continuous advocacy that led to a better-but-still-flawed final rule. Member David Harris, PTA, MBA, authored the piece (he's chief delegate of the APTA PTA Caucus), which is not only valuable for the history it provides but also as an example of the legislative and policymaking twists and turns that affect rulemaking.