AOTA Outlines Concerns on OTA Payment Modifiers

CMS accepting comments for one more week

With time running out for OTs to express their concerns on the implementation of the 2020 Medicare Physician Fee Schedule Proposed Rule (MPFS), AOTA strongly encouraged their members to make their voices heard before September 27, the final day of the comment period.

The MPFS would require reporting when an OTA performs a service in whole or in part, defined as exceeding 10 percent of the service. This will lead to a 15 percent payment reduction for such services beginning in the year 2022. 

AOTA’s main concerns exist in three separate areas:

  • Concurrent Services. CMS is proposing that when an occupational therapist is furnishing care and requires the skilled assistance an OTA, the entire service provided by the therapist will be subject to a 15% payment adjustment, even though the therapist was present for the entire visit. This policy includes both timed and untimed (evaluations) services.
  • Units of Service Furnished Separately: The 2020 MPFS proposes applying the 15% payment adjustment to services provided by an occupational therapist when the assistant and the therapist each separately furnish units of the same service (CPT code)
  • Administrative Burden: The proposed documentation requirements associated with the new modifiers is burdensome and conflicts with new efforts to place “patients over paperwork.” CMS is proposing that the outpatient therapy provider be required to add a statement in the medical record for each line of every claim to explain why the modifier was or was not used.

You can view the entire document on AOTA’s website, but keep in mind that time is of the essence!

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