CMS Proposed Rule Revisions for Calendar Year 2020: Part One

Author: Paul Singh
Published: 

Annual Therapy Threshold, KX Modifier & Targeted Medical Review Threshold

The year 2020 could see some new CMS rule revisions that could affect your physical therapy practice.  Let’s take a look at some of these proposed rules, specifically the ones that affect 410.59 (outpatient occupational therapy) and 410.60 (physical therapy and speech-language pathology).  These proposed rule changes are an attempt to incorporate the changes made by section 50202 of the Bipartisan Act (BBA) of 2018.

Annual Therapy Threshold

A new paragraph (e)(1)(v) is likely to be added to 410.59 and 410.60 to clarify that the specified amounts of annual per-beneficiary incurred expenses are no longer applied as limitations, but as threshold amounts which services require, as a condition of payment, inclusion of the KX modifier, and that use of the KX modifier confirms that the services are medically necessary as justified by appropriate documentation in the patient’s medical record.

Use of the KX Modifier

Another likely revision will be an amendment in paragraph (e)(2) in 410.59 and 410.60.  This amendment will specify the therapy services and amounts that are accrued for purposes of applying the KX modifier threshold, including the continued accrual of therapy services by critical access hospital (CAHs) directly or under arrangements at the PFS-based rates.

Targeted Medical Review Threshold

Another proposed amendment to 410.59 and 410.60 is in paragraph (e)(3).  This applies to the medical review threshold to clarify the threshold amount and the applicable years for both the manual MR process originally established through section 3005(g) of the Middle Class Tax Relief and Job Creation Act of 2012 (MCTRICA).  It also applies to the targeted MR process established by the Medicare Access and CHIP Reauthorization Act (MACRA) and includes the changes made through section 50202 of the BBA of 2018.

While CMS changes can be confusing and may affect your current billing process, you can always count on our all-inclusive billing solution to be one step ahead of any new changes.  Visit our website or contact one of our friendly associates to show you why StrataPT provides an unmatched level of customer service and the #1 accounts receivable collection rates in the industry.

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