As an OTA practitioner, academic, student, or supporter of the profession, you may be aware of the legislative and regulatory changes affecting Medicare OTA payment. It is our aim to provide you with as much information as possible about this change.
The Medicare OTA payment differential goes into effect on January 1, 2022. In the Medicare Physician Fee Schedule (MPFS) final rule, the Centers for Medicare & Medicaid Services (CMS) finalized their policy on when the CO modifier should be applied on claim forms. Understanding how and when to apply the modifier will be crucial to ensure proper reimbursement in 2022.
The modifier applies when:
- OTA performs entire 15-minute unit of service independently
- OTA performs more than 10% of a 15-minute unit (exception: 8-minute rule used for final unit)
- OTA performs 8 minutes or more of final unit of service
- OTA independently performs more than 10% of an untimed service
The modifier DOES NOT apply when:
- Services are performed concurrently with an OT
- Non-therapeutic tasks are used
- Total time spent by OTA does not reach more than 10% of untimed service
- Total time spent by OTA does not reach more than 10% of a 15-minute unit
- OT performs 8 or more minutes of final unit of service
This change currently only affects Medicare Part B, Tricare, Humana, and United Healthcare payments. Taking a team-based approach has helped occupational therapy professional growth and will remain a valuable care model. OTAs will be as much a part of the provision of services on January 1, 2022, as they are on December 31, 2021.