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CMS NCCI

As of January 1, 2020, it was announced by the Center for Medicare and Medicaid Services (CMS) and the contractor that is in charge of the National Correct Coding Initiatives (NCCI) that two commonly billed therapy CPT codes would no longer be permitted to be used in conjunction with the physical and occupational therapy evaluation codes. Capitol Bridge, LLC added the two treatment codes therapeutic activity (97530) and group treatment (97150) to the NCCI PTP edit list. What this means is when a physical therapy evaluation (97161, 97162, 97163) or an occupational therapy evaluation (97165, 97166, 97167) is completed and billed, therapeutic activity and/or group treatments cannot occur on the same day and vice versa. This does not only apply to the single discipline completing the evaluation, but across disciplines. Not only is this in conflict with CMS policy of allowing subsequent treatment to be completed on the day of an evaluation, but this has the potential to cause conflict in the delivery of appropriate care between disciplines.

In addition to restricting the use of these treatment codes, the contractor also added manual therapy (97140) to the list and require the use of the 59 modifier, the modifier that's used to indicate that a code represents a service that is separate and distinct from another service to which it is paired, whenever it is billed in conjunction with the physical or occupational therapy evaluation codes.

There is concern that the addition of these edits may be an early indication that CMS may eventually develop a policy that fully restricts the services that can be provided to physical and occupational therapy patients by limiting or removing the ability to provide treatment on the same day of service as an evaluation. This would be detrimental to the care our patients receive.

Professional and trade organizations, including the American Physical Therapy Association, the American Occupational Therapy Association, and National Association for the Support of Long Term Care, as well as others have spoken out against these edits as they are in conflict with current policies as well as the ability to provide and appropriately bill/code the necessary treatments that patients need. Capitol Bridge, LLC provided little notice with these additions and neither Capitol Bridge, nor CMS has released any statement or explanation on the rationale behind the addition of these codes at this time. These organizations have composed and sent letters to Capitol Bridge, LLC, urging changes to occur prior to the next quarterly update to reduce the impact it has on patients, care delivery and the need to train and retrain therapists.

It is imperative to communicate these and other concerns to Capitol Bridge, LLC, in hopes that there will be a resolution that allows patients to continue to receive the care they need and deserve. Electronic correspondences can be sent to: [email protected]