The 2025 Proposed Rule was released on July 10, 2024. There will be significant changes in operations practice for Physical Therapy (PT) and Occupational Therapy (OT). There will need to be modifications to the Medicare Benefit Policy Manual (MBPM) Section 220, if the rule is finalized in November 2024, to be effective 1/1/2025. The press release for the 2025 Proposed Rule provides specifics. Here are two of the therapy changes that were outlined in the proposed rule:
Supervision Policy for Physical Therapists (PTs) and Occupational Therapists (OTs) in Private Practice
For CY 2025, we are proposing a regulatory change to allow for general supervision of physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) by PTs in private practice (PTPPs) and OTs in private practice (OTPPs) for all applicable physical and occupational therapy services. This proposed change will give PTPPs and OTPPs more flexibility in meeting the needs of beneficiaries and safeguard patient access to medically necessary therapy services, including those experiencing challenges accessing these services in rural and underserved areas; and it will align with general supervision of PTAs and OTAs by PTs and OTs who work in institutional providers.
Certification of Therapy Plans of Treatment with a Physician or NPP Order
For CY 2025, CMS is proposing amendments to the certification and recertification regulations to lessen the administrative burden for therapists and physician/NPPs. These changes, if finalized, would provide an exception to the physician/NPP signature requirement on the therapist-established treatment plan for purposes of the initial certification in cases where a written order or referral from the patient’s physician/NPP is on file and the therapist has documented evidence that the treatment plan was transmitted to the physician/NPP within 30 days of the initial evaluation. CMS is also soliciting comments, as suggested by interested parties, as to the need for a regulation (a) addressing the amount of time during which the physician/NPP who has written an order for therapy services could make changes to the therapist-established treatment plan by contacting the therapist directly, and (b) whether there should be a 90-day (or other) limit to the physician/NPP order extending from the order date to the first date of treatment/evaluation by the therapist.
If you treat and bill for outpatient PT and OT in the private practice setting, stay tuned for the Final Rule changes for supervision requirements for assistants! As well as, the requirements for physician/NPPs certification. If you have questions, please contact Kay Hashagen, PT, MBA, RAC-CT at [email protected] or (410) 777-5999.
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