The Centers for Medicare & Medicaid Services (CMS) has introduced a significant update regarding the Medicare Part B physical therapy plan of care (POC) signature requirements, effective January 1, 2025. This policy change, announced within the 2025 Medicare Physician Fee Schedule final rule, provides a welcome exception to the previously mandatory signature for initial certification of a physical therapy plan of care. This update aims to streamline administrative processes and reduce burdens for physical therapists and referring providers.
Under the revised guidelines, a signed and dated order or referral from a physician or a qualified nonphysician practitioner can now fulfill the certification requirements. This is applicable when a patient is referred for physical therapy services. To utilize this exception, the order or referral must be documented within the patient’s medical record. Crucially, there must also be evidence confirming that the physical therapy plan of care was submitted to the referring provider within 30 days following the initial patient evaluation.
Previously, securing reimbursement for Medicare Part B outpatient therapy services necessitated a more cumbersome process. Physical therapists were not only required to submit the plan of care to the referring provider within the 30-day timeframe but also had to obtain a signed and dated copy of the POC from the provider as proof of certification. This often involved repeated follow-ups to acquire the necessary signatures, sometimes leading to claim denials for services that were medically necessary, solely due to the absence of timely physician signatures.
The new exception significantly shifts the dynamic. Once the physical therapist transmits the plan of care, the responsibility now rests on the referring provider to either sign and return the POC or suggest modifications. If neither action is taken, the referring provider’s silence is considered as acceptance of the submitted plan of care. This updated rule underscores a greater reliance on the clinical expertise of physical therapists. Moving forward, the primary documentation requirement is evidence of the initial order or referral, simplifying the certification process for Medicare Part B physical therapy services.
Citations: 42 CFR Part 424, Subpart B; 89 Fed. Reg. 97710, 97912-97918; Medicare Benefit Policy Manual, Ch. 15, Sec. 220.1.3, 220.3.
