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3 Ways to “Counter the Cut” from CMS (Centers for Medicare & Medicaid Services) in 2024

As expected, CMS will reduce payment by 3.4% in 2024 for therapy services (unless Congress pulls off an unlikely miracle). The Medicare therapy threshold will be slightly increased to $2,330 (PT/SLP still share this amount and OT has their own bucket). Another year and another reduction in reimbursement, but below are three helpful strategies for your practice to counter the cut!


First, therapists now have three caregiver training services codes that are approved for reimbursement. Most therapists have wondered how to capture this educational component but were never satisfied with where this category of service lived. Let’s explain each one.


97550: Not to be confused with 97750 which requires an individually written report for each physical performance test or measurement, this new code 97550 is for caregiver training which facilitates a patients’ functional performance in either the community or home location. This code is used for the first 30 minutes and is a direct 1:1 code. Examples include training for functional transfers, safety, or mobility.


97551: For each additional 15 minutes of direct caregiver training, this code is applied.


97552: This code is used for group caregiver training sessions where multiple sets of caregivers are being educated on strategies and techniques for functional transfers, safety, or mobility.


Audit Warning: Just like we include a statement in every evaluation indicating the patient consents and understands the plan of care that has been established, these codes also require a similar documented consent.


Second, telehealth is still on the table for reimbursement. Although not permanently added, we are still on the Category 3 list through the end of 2024. Stay focused on the place of service code and modifier starting 1/1/2024: Outpatient settings should be listing place of service 11 for the clinic or 12 if the patient is home; you are to list the location where the patient normally would have been seen. Modifier 95 is the correct code for outpatient locations. Note: place of service 10 is reimbursed at the non-facility rate, while place of service 2 is paid at the facility rate.


Finally, remote therapeutic monitoring (RTM) has received special attention with their general supervision allowance in outpatient settings. This special carve-out allows PTAs and OTAs to continue to offer their services without the burden of direct supervision that has been applied to outpatient therapy. The leniency has been extended through the end of 2023 and allows for supervision of PTAs and OTAs to require only immediate availability though real-time audio and visual interactive telecommunications rather than the official direct supervision listed. Why a proven method to reduce administrative and operational burdens has not been permanently changed is bewildering. Only outpatient private practices still have a direct supervision requirement for PT->PTA and OT->OTA, and yet the licensure and educational requirements are exactly the same regardless of practice setting for therapists.


So, if you’re still considering all of the opportunities to include a team approach to help counter the cut from CMS in 2024, start with these 3 simple ways that are likely already being provided but not captured on billing. Now you can capture those caregiver training minutes that have been challenging to justify on the documentation notes. When cancellations due to weather, health issues or other restrictions prevent a patient from attending therapy, you now have another year in 2024 to perform and get reimbursed for telehealth services. Don’t forget to enhance your home exercise programs with RTM services. Find a platform that makes sense for you. Since PTAs and OTAs have full access to these patients without the supervision burden, it’s time to increase revenue that will help mitigate this ongoing challenge of reimbursement cuts.


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