CMS Posts Two Transmittals/One Change Request Impacting Part B Therapy

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare®

Updates to Reflect Removal of Functional Reporting Requirements and Therapy – Transmittal 4214/Change Request 11120 was posted on Friday, January 25, 2019.  “The purpose of this Change Request (CR) is to update chapter 5 to reflect recent changes in outpatient therapy service billing instructions and payment policies related to the Bipartisan Budget Act of 2018 and the calendar year 2019 Medicare physician fee schedule final rule.”  The effective date of these changes is January 1, 2019 while the implementation is effective February 26, 2019. 

“CR 11120 updates both the Medicare Benefit Policy Manual and Medicare Claims Processing Manual to reflect recent changes in outpatient therapy services billing instructions and payment policies related to the Bipartisan Budget Act of 2018 and the Calendar Year (CY) 2019 Medicare Physician Fee Schedule (MPFS) Final Rule. These policy revisions include: (a) the repeal of the application of the outpatient therapy caps and the retention of the therapy cap amounts as thresholds of incurred expenses above which claims must include a modifier to confirm services are medically necessary as shown by medical record documentation; and, (b) the discontinuation of the functional reporting requirements. Please make sure your billing staffs are aware of these changes.”

The last 12 pages of this 16-page transmittal updates Chapter 5 of the Medicare Claims Processing Manual – Part B Outpatient Rehabilitation and CORF/OPT Services.  The changes are identified in red font.  Review the corresponding MLN Matters Number: MM11120 for additional information.  “This MLN Matters Article is intended for therapists, physicians, certain nonphysician practitioners and other providers of therapy services – including physical therapy (PT), occupational therapy (OT) and speech-language pathology (SLP) services − who submit professional or institutional claims to Medicare Administrative Contractors (MACs) for therapy services provided to Medicare beneficiaries.”Transmittal 255/Change Request 11120, also posted on January 25, 2019, provides updates Chapter 12 of the Medicare Benefit Policy Manual – Comprehensive Outpatient Rehabilitation Facility (CORF) Coverage. The last 33 pages of this 39-page transmittal provides changes to this chapter in red font.  MLN Matters Number: MM11120 (hyperlink provided in the paragraph above) speaks to both transmittals relative to the same CR.