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New Medicare PTA and OTA Modifiers - General Rule
January 2020: PTA (CQ) and OTA (CO) modifiers must be used when services are provided “in whole or in part” by therapy assistants.
January 2022: Payment for services provided “in whole or in part” by a therapy assistant will be reduced to 85% of the Part B payment.
The modifiers must be used for all outpatient therapy services and providers that submit Part B claims:
Critical access hospitals will not be subject to the reduced payment rate but may still need to use the modifiers.
The New Modifiers
PTA Modifier CQ: Outpatient physical therapy services furnished in whole or in part by a physical therapist assistant.
OTA Modifier CO: Outpatient occupational therapy services furnished in whole or in part by an occupational therapy assistant.
Key Changes in the Final Rule
Application of the Modifiers
When the modifiers apply
Services wholly furnished by PTAs or OTAs without physical or occupational therapists.
When at least 10% of a service or unit of a service is provided by a PTA or OTA without a therapist.
When the modifiers do not apply
When therapists exclusively furnish services without the involvement of PTAs/OTAs.
When therapists furnish a service with an assistant and provide care to the patient for the entire duration of the service.
84 FR 40482