The CMS proposed rule for 2025 is here, and it brings several significant updates that physical therapy professionals and practice owners need to be aware of. With adjustments to telehealth services, supervision requirements, and new care management codes, these changes will shape the way physical therapy services are delivered and reimbursed in the coming year. In this article, we’ll break down the key components of the 2025 proposed rule and explain how it impacts physical therapy practices, making it easier for you to understand, implement, and streamline these changes within your clinic.
Each year, the Centers for Medicare & Medicaid Services (CMS) updates its Medicare Physician Fee Schedule (MPFS), which dictates the reimbursement rates and policies for healthcare services covered under Medicare. These changes often include revisions to telehealth services, supervision rules, and billing codes, all of which directly impact physical therapists (PTs) and physical therapy assistants (PTAs). For 2025, CMS has proposed a number of changes aimed at enhancing the flexibility and accessibility of physical therapy services, particularly in the areas of telehealth and supervision.
One of the most impactful changes in the CMS proposed rule for 2025 is the reduction in average payment rates under the MPFS. CMS is proposing a 2.93% reduction in these rates, which means the conversion factor for 2025 will be lowered to $32.36 from the 2024 rate of $33.29. This decrease in reimbursement could pose financial challenges for physical therapy practices, especially for those with a significant Medicare patient base.
During COVID-19, CMS introduced several flexibilities around telehealth services, allowing physical therapists to provide certain services remotely. While many of these flexibilities are set to expire at the end of 2024, CMS has proposed extending key components through 2025, specifically around direct supervision.
In physical therapy, CMS direct supervision typically requires a supervising physician or practitioner to be present in the same office suite and immediately available to assist as needed. However, under the CMS proposed rule for 2025, physical therapists can continue to meet the "immediate availability" requirement for direct supervision through real-time audio and video communication.
This allows PTs and PTAs to conduct services under supervision without requiring the physical presence of the supervising practitioner, provided the technology is in place. This extension offers more flexibility, particularly in rural or underserved areas where access to onsite supervision may be limited.
Another significant update in the CMS proposed rule is the revision to the definition of “telecommunications system.” Starting in 2025, CMS proposes that telehealth services can include audio-only communications in cases where patients cannot or choose not to use video technology. This change applies to certain telehealth services provided to patients in their homes, ensuring that physical therapists can still offer care through telehealth even when video isn’t an option.
For practices that have integrated telehealth into their service offerings, this change can expand access to care, especially for older adults or patients in areas with limited broadband access. However, these services will need to be billed using the appropriate CPT modifiers, such as "93," which indicates that the service was provided through audio-only communication.
In addition to telehealth and supervision updates, CMS is introducing new billing codes that physical therapists can use for caregiver training services. These codes, including CPT 96202 and CPT code 96202, are designed to reimburse providers for the time spent training caregivers in patient care strategies and techniques. Specifically, CPT 96202 applies to group behavior management or modification caregiver training sessions. This is particularly important for physical therapists working with patients who require at-home care, as it ensures that therapists are compensated for the critical service of caregiver education.
These new codes provide an opportunity for physical therapy practices to expand their service offerings and bill for training that was previously difficult to quantify. Ensuring that caregivers are properly trained to assist patients at home can improve patient outcomes and reduce the need for additional medical interventions.
One of the more permanent changes proposed by CMS is the allowance for CMS direct supervision via audio-video technology for certain services. This flexibility will be made permanent for services provided incident to a physician’s service when auxiliary personnel, such as PTAs, are involved. For physical therapy practices, this means that certain services can be provided under "virtual supervision" without needing the supervising practitioner to be physically present in the treatment facility.
This is particularly relevant for practices where PTAs are delivering care under the supervision of a physical therapist. It reduces the administrative burden of always having the supervising therapist onsite and offers greater flexibility in how services are scheduled and delivered.
Process measures are essential indicators of healthcare quality that track whether specific steps in patient care are being followed to achieve optimal health outcomes. For physical therapy practices, these measures guide clinicians on delivering consistent and effective treatments, ensuring compliance with CMS standards. The CMS proposed rule for 2025 introduces changes to existing process measures and adds several new ones, reflecting the continued focus on improving the quality of care in physical therapy.
In the 2025 proposed rule, CMS has updated and introduced several process measures to enhance the accuracy and consistency of patient care documentation and interventions. These changes apply to physical therapy and other rehabilitation services, directly impacting how clinicians report patient outcomes, document interventions, and perform assessments.
Here’s a breakdown of the new and updated process measures that physical therapy professionals need to know:
The Rehabilitative Support for Musculoskeletal Care MVP program marks a significant shift in how physical therapy professionals will report and measure quality. CMS’s Merit-based Incentive Payment System MIPS Value Pathways (MVPs) represent the future of quality reporting for rehabilitation services, offering a streamlined approach that aligns care with outcome-driven metrics.
In 2025, CMS has introduced new quality measures to support musculoskeletal care, making it easier for physical therapists to demonstrate the value of their services. Here’s what you need to know:
With the addition of these new measures and updates, physical therapy professionals need to focus on making the most of the CMS proposed rule changes. Here’s how to make these adjustments easier and more streamlined for your practice:
With the introduction of new CPT codes like CPT 96202, which covers group behavior management and modification training for caregivers, physical therapy practices can now bill for these essential services. Educating caregivers on how to assist patients with at-home exercises and functional tasks has always been a critical part of rehabilitation, but until now, it was difficult to capture this value in billing.
To streamline this process:
The CMS proposed rule extends the allowance for CMS direct supervision through real-time audio-video technology. This means that physical therapists can continue to provide oversight for PTAs or other auxiliary staff without being physically present, as long as they are immediately available via audio-video communication.
To make the most of this flexibility:
The continued evolution of MIPS Value Pathways (MVPs) represents a shift toward more streamlined and outcome-based quality reporting. For physical therapists, the focus on Rehabilitative Support for Musculoskeletal Care MVP offers an opportunity to showcase the value of your treatments through specific quality measures that align with your daily practice.
To streamline your MIPS participation:
The changes to process measures for 2025 emphasize the need for accurate and comprehensive documentation in physical therapy practices. The updated Quality #130 on medication documentation and Quality #155 on fall prevention plans are examples of how thorough record-keeping can directly impact your compliance and reimbursement.
To ensure you’re compliant with these new and updated measures:
Managing the new quality measures, CPT codes, and telehealth flexibilities can be challenging, but leveraging technology can make these processes more efficient. Physical therapy software platforms like PtEverywhere offer solutions that streamline scheduling, documentation, and billing, helping you stay compliant with the CMS proposed rule changes.
Here’s how to optimize your practice’s workflow with technology:
Implementing the changes in the CMS proposed rule can be complex, but PtEverywhere, a comprehensive physical therapy software, simplifies this process. Here's how PtEverywhere can help your practice:
PtEverywhere offers a robust platform to navigate these changes with ease, helping your practice stay compliant and efficient.
With the CMS proposed rule for 2025 introducing both opportunities and challenges, it’s essential to take proactive steps to ensure your practice is ready. From understanding the new process measures and quality reporting requirements to taking advantage of telehealth flexibilities and new billing codes, this year’s changes require careful attention to detail.
By updating your billing practices, training staff on new telehealth and supervision policies, and leveraging technology to streamline compliance, physical therapy practices can successfully navigate these regulatory changes. While the reduction in payment rates may pose financial challenges, the flexibility in supervision and new service offerings like caregiver training can help offset some of the impact, ensuring that you continue to provide high-quality care for your patients while maintaining a thriving practice.