Beginning Jan. 1, 2020, private practices have to use the CQ modifier (for PTAs) and CO modifier (for COTAs) on each CPT code where the PTA or COTA provided more than 10% of the service independent of the PT or OT. For t15-minute timed codes, this equates to 2 minutes or more of the time. The CQ modifier must be affixed to the claim line of the service alongside the GP therapy modifier to identify services furnished under a physical therapy plan of care. APTA’s website provides more details about this rule and clinical scenarios to walk through to determine when you have to add the modifier. Payment for services provided by PTAs and COTAs will be reimbursed at 85% of the fee schedule. The official source for the rules is Chapter 5 of the Medicare Claims Processing Manual.
Now is the time to start looking at how you are using assistants and incorporating this new rule into your budget. It won’t be long before commercial insurance companies will be applying this same rule to their reimbursement policies. Watch for amendments to your contracts that implement this rule!