Important Update: Medicare Part B OTA Payment Change Effective January 1, 2022

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.

Here are some key points to note to help you prepare for this change 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.

Remember that a collaborative approach has always been a hallmark of occupational therapy practice and will continue to be a valuable care model. OTAs will remain as much an integral part of the provision of services on January 1, 2022 as they are on December 31, 2021.

We invite you to share this important information with your colleagues, peers, and advocates.

Special thanks to the OTA Confab and Dr. Kathy Bearfield, DHSc, COTA/L,  for organizing this information.



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