The Centers for Medicare and Medicaid Services (CMS) implemented new modifiers that could impact your practice, these are the CQ and CO modifiers. If your practice utilizes physical therapy assistants and/or occupational therapy assistants, you will need to know when and how to apply the CQ and/or CO modifier.  

To read the entire final rule from Medicare, please visit this site. We are here to save you from reading the 2000+ page document and provide you with the pertinent information.  

Beginning with dates of service on and after January 1, 2020, providers of outpatient physical and occupational therapy will be required to add the CQ (for PTA) or CO (for OTA) modifier when “outpatient therapy services are furnished in whole or in part” by an OTA or PTA. It is also important to note that the GP, GO, and KX modifiers will continue to be used in conjunction with these additional modifiers.  

What qualifies as ‘in whole or in part’? According to CMS, “A service is considered to be furnished in whole or in part by a PTA or OTA when more than 10 percent of the service is furnished by the PTA or OTA.” The de minimis standard does not apply when PT’s and PTA’s (or OT’s and OTA’s) are providing treatment to patients at the same time. This only applies when an OTA or PTA provide treatment independently. We’ve created a calculator to help you determine if a CO or CQ modifier is required, which you can download here. 

If a PT and PTA (or OT and OTA) provide treatment to the same patient within the same visit, the CO and CQ modifiers are only required for the units that were performed by the assistant. For example, if a patient receives 20 minutes of therapeutic exercise from a PT, and 10 minutes of gait training from a PTA, the two units of therapeutic exercise should not include the CQ modifier, while the one unit of gait training would require the CQ modifier. 

If you or your staff have questions about the CO and CQ modifiers, reach out to the rehab therapy billing experts at Account Matters at 508-422-0233 or email us at info@accountmattersma.com.