Introduction:

Every year, therapists wait anxiously for the Centers for Medicare and Medicaid Services (CMS) to release its Physician Fee Schedule Final Ruling, a document exceeding 2,000 pages that demands meticulous scrutiny from compliance experts. In our unwavering commitment to easing the burden for busy rehab therapists, we have meticulously sifted through the 2,700 pages of the 2024 CMS Physician Fee Schedule. Join us as we outline the key highlights that will shape the landscape for rehab therapists in the upcoming year.

Key Highlights:

1.Reduction in the Conversion Factor:

Once again, the conversion factor sees a decrease. The final rule for 2024 announced a reduction in the conversion factor for the PFS calendar year to $32.74, marking a 3.4% decrease from the current year’s factor of $33.89.

2.Changes in Therapy Thresholds:

Rehab therapists eagerly await the announcement of new therapy thresholds each year. For CY 2024, the KX modifier threshold for combined physical therapy and speech-language pathology services is set at $2,330, and occupational therapy services will follow suit.

3.Supervision Rules Evolution:

The rules governing supervision, whether direct or general, have been evolving, especially with the introduction of remote therapeutic monitoring (RTM) amid the public health emergency. The 2024 final rule allows PTs and OTs in private practice to utilize general supervision for assistants when employing RTM services, extending through the end of 2024.

4.Compensation for Caregiver Training:

CMS recognizes the value of caregiver training and introduces five new CPT codes covering caregiver training services within therapy plans of care. Payment is extended to family members, friends, and neighbors providing unpaid assistance to individuals with chronic illnesses or disabilities.

The codes applicable to Physical Therapists (PTs), Occupational Therapists (OTs), and Speech-Language Pathologists (SLPs) are as follows:

• 97550: Caregiver training in strategies and techniques to enhance the patient’s functional performance in the home or community (e.g., activities of daily living (ADLs), instrumental ADLs (IADLs), transfers, mobility, communication, swallowing, feeding, problem-solving, safety practices) without the patient present, face-to-face; initial 30 minutes.
• 97551: Each additional 15 minutes listed separately, in addition to 97550, for primary services.
• 97552: Group caregiver training in strategies and techniques to enhance the patient’s functional performance in the home or community (e.g., activities of daily living (ADLs), instrumental ADLs (IADLs), transfers, mobility, communication, swallowing, feeding, problem-solving, safety practices) without the patient present, face-to-face with multiple sets of caregivers.

5.Extension of Telehealth Services:

Telehealth services for rehab therapists have been granted a temporary extension through the end of CY 2024. Despite ongoing discussions, PT, OT, and SLP services remain in category three for telehealth distinctions.  

While there have been calls to elevate these services to category one or two distinctions, CMS has maintained them at category three, citing uncertainties about the complete feasibility of therapy services via real-time audio/video technology.

6.Clarifications on Place of Service (POS) Codes:

CMS addressed the confusion surrounding POS codes for telehealth services, emphasizing the application of modifier 95 for PT, OT, and SLP distant site practitioners, ensuring payment at the non-facility rate until the end of CY 2024.

Please be sure to keep in mind that Modifier 95 is significant in indicating that the applied code was delivered through a “synchronous telemedicine service.” CMS defines this service as a real-time interaction occurring between a physician or other qualified healthcare professional and a patient situated at a distant site from the healthcare professional. This distinction is crucial in recognizing and appropriately compensate healthcare services provided through telemedicine, particularly those involving real-time, two-way communication between the healthcare provider and the patient.

7.Changes in MIPS for PTs, OTs, and SLPs:

MIPS sees significant changes, with the performance threshold remaining at 75 points for the 2024 performance year. Notably, automatic reweighing of the Promoting Interoperability category will no longer apply to PTs, OTs, and SLPs. The performance period for this category has also been extended to 180 continuous days.

8.Updates to PT/OT Specialty Sets:

CMS continues to make adjustments to specialty sets, introducing new measures while removing others. Practitioners should take note of the changes in specialty sets for PTs and OTs in 2024.

While the introduction of the Musculoskeletal (MSK) MIPS Value Pathway (MVP) for 2024, particularly focusing on Low Back Pain, is a notable advancement, there are noteworthy concerns raised about its current structure. Commenters have emphasized the need to exercise caution and consider delaying the finalization of the MSK MVP until 2025. The primary recommendation is to incorporate harmonized Limber/IROMS measures to enhance the comprehensiveness of the MVP.

As it stands, the 2024 version of the MVP relies heavily on Functional Outcomes and Rehabilitation Measures (FOTO) for seven out of the 10 quality measures. This reliance on FOTO measures may present accessibility challenges for a significant number of physical therapists. Moreover, there is the potential for additional expenses related to accessing these measures.

Healthcare practitioners are encouraged to stay vigilant and engaged in ongoing discussions surrounding these concerns. Monitoring developments, participating in industry dialogues, and advocating for improvements in the MVP construction are essential steps to ensure that the MSK MVP effectively addresses the needs of rehabilitation therapists while minimizing potential challenges and financial implications associated with measure accessibility.

9.Awaiting Ruling on Multiple Procedure Payment Reduction (MPPR):

In a recent development, CMS has disclosed a potential modification to the multiple procedure payment reduction (MPPR) for the practice expense (PE) relative value units (RVUs) of 19 therapy Current Procedural Terminology (CPT) codes. Despite this mention earlier in the year, the final rule has been released without a conclusive decision on this matter. The fate of these proposed changes is now pending review and a ruling from the Relative Value Update Committee (RUC), anticipated to take place in early 2024.

We know navigating through the dense acronyms and technical language in the 2024 CMS final rule can be a daunting task even for the most seasoned biller and let’s be honest what physician even has time for that nowadays?

That’s why despite the lack of user-friendly options available to dissect the 2024 updates, we hope that our ongoing efforts to provide an easy-to-read overview will contribute to a clearer understanding and smoother transition to the updates 2024 has in store.

Stay tuned to our blog for ongoing updates and industry announcements as these new rules undergo further clarification.