The Annual Medicare Physician Fee Schedule (MPFS) Proposed Rule 2025: What PTs Need To Know And How To Plan For Success

The annual excitement for the new proposed Medicare updates to our profession is likely met with anxiety and the expectation of bad news. But there is good news because for 2025, nothing really is new!  

• The PTA general supervision status remains the same with a virtual audio/video allowance.
• The KX modifier amount adjusts slightly higher again to $2,410 (PT/SLP combined limit as usual).
• CPT codes will sadly be reduced again on average by almost 3%, but the greatest area of concern for everyone reading should be the 5.46% reduction for CPT code 97530.
• Like last year, valuable caregiver training services will add 3 more options to allow for billing while the patient is now present during the service. The new 2024 CPT codes, 97550, 97551, and 97552, previously only allowed for this service while the patient was absent (see below for a review of these three codes). 
  • 97550 - Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem-solving, safety practices), face to face; initial 30 minutes.
  • 97551 - Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem-solving, safety practices), face to face; each additional 15 minutes
  • 97552 - Group caregiver training (multiple patients’ caregivers e.g. three sets of caregivers representing three different patients) in strategies and techniques to facilitate the patient's functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem-solving, safety practices), face to face with multiple sets of caregivers.

The administrative burden of collecting a signed plan of care may be slightly adjusted if a referral is made (it’s unclear in which direction this brings the level of professional autonomy). We will know more when the final Rule is released at the end of October 2024.

• The quality improvement program known as MIPS is always a moving target activity. The 75-point threshold will hold steady for 2025, but MVPs will be here shortly just to keep everyone guessing.

These proposed updates/issues demand that each of us advocate on behalf of our clinics and profession by voicing our concerns. Stay engaged with the profession and advocate for a change to this constant game of reflexive strategy. Sign-up and stay connected with APTA.  

3 Helpful Steps to Succeed Despite the MPFS Proposed Rule

Demonstrate Value and Meaning to Patients

Start with demonstrating how changes that were made (i.e., telehealth privileges) are still valuable and meaningful to our patients who need them. We can do this by incorporating this line of service into the conversation for every (clinically appropriate) patient on the schedule. If a patient is trying to cancel or reschedule an appointment/treatment option, try offering telehealth therapy that works for them. 

Now is the time to start if you’re not already using or considering an AI documentation assistant. Incorporating the line of service into conversations, where appropriate, is easier when ambient listening is catching your patient conversation and generating documentation for you.

Darci Whitehorne, a PT using PredictionHealth’s AI scribe Sidekick, says, "I have a much more comprehensive picture of my visit with Sidekick because there are so many things that I educate and talk about that I don't capture in my own notes. It's a much better window to skilled care."

Don’t Leave RTM Services on the Table

For almost two years, remote therapeutic monitoring (RTM) services have been available with a surprising cherry on top for this year. The PT-> PTA direct supervision standard for RTM in outpatient therapy was adjusted and downgraded to only requiring general supervision. With the average reimbursement per episode of care at around $130-$150 per patient, this potential for revenue should not be ignored. Regardless of hiring in-house clinical staff or outsourcing to a 3^rd party vendor for the RTM service line, this opportunity to capture patient engagement, clinical outcome, and overall proven patient retention is something each clinic should strongly consider. 

In the same way that an AI scribe can auto-generate your notes and documentation for you, consider AI tools that can also monitor your CPT codes to track how often your therapists are using an RTM visit, which can be challenging to see without tools like PredictionHealth’s Practice Intel platform. Even better is when it’s all housed together in one platform, so you don’t have to purchase, train, and implement multiple tools. 

Enhancing the Patient Experience

And finally, take a proactive approach to enhancing the patient experience inside the clinic by considering a final “out of the box” or even “out of the clinic” concept. In-home physical therapy is often associated with the word “agency.” Rules and regulations are specific to these agencies; however, speaking with a liability specialist like CM&F can quickly help you discover if you’re protected when offering In-Home Therapy Services. Risk & Compliance Analytics offers its members a unique audit check list that guides providers on areas of exposure and how to focus this line of service.

Leverage Best Practice Tools for Success 

Making the most of your opportunities to be successful within the requirements of MPFS can be simpler and faster with some of the tools that are available to PTs and Rehab Therapy practices today. AI platforms like PredictionHealth offer a powerful engine that can help take the guesswork out of documentation compliance and CPT coding. 

Leverage AI to help your therapists quickly and accurately select CPT codes that are the best reflection of the care they have provided. An analytics platform like Practice Intel can give you insight into documentation compliance risks and gaps and opportunities to either select a more accurate CPT code based on the documentation or support the CPT code selections better in the documented justification.

About the Author

Daniel Hirsch PT, DPT, CHA, OHCC, COCA is a licensed physical therapist with over 15 years of risk management and compliance experience. He is CEO of Risk & Compliance Analytics LLC, a comprehensive compliance solution for outpatient therapy practices. He has experience in both Property & Casualty and Life & Health Insurance, has served as the Chief Compliance Officer for large multi-state Physical Therapy practices, is an educator on Therapy Ethics and the Profession, and has numerous compliance and ethics certifications.