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.
Understanding the CMS Proposed Rule 2025
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.
Key Changes in the CMS Proposed Rule for 2025
1. Reduction in Payment Rates
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.
2. Telehealth Flexibilities and Supervision Requirements
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.
3. Expansion of Audio-Only Telehealth Services
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.
4. Introduction of New CPT Codes for Caregiver Training
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.
5. CMS Direct Supervision: Permanent Flexibility for Certain Services
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.
Understanding the Process Measures in the CMS Proposed Rule 2025
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.
Key Changes to Process Measures for 2025
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:
New Process Measures:
- Quality #130: Documentation of Current Medications in the Medical Record
- This process measure has been updated to improve efficiency by removing age criteria, making it applicable to all patients. It focuses on documenting current medications, dosage, route, and frequency to ensure comprehensive clinical communication and prevent patient harm.
- Quality #155: Falls: Plan of Care
- This measure has transitioned from Medicare Part B Claims Measure Specifications to MIPS CQM Specifications. It ensures that patients at risk of falls have a documented plan of care, improving safety and preventative care in rehabilitation settings.
- Quality #181: Elder Maltreatment Screen and Follow-Up Plan
- Although not directly related to physical therapy, this measure is crucial for screening and addressing elder maltreatment, adding emergency department encounter codes for better data capture.
- Quality #182: Functional Outcome Assessment Tool
- This measure recognizes that not all patients can complete self-report questionnaires for functional limitations. Physical therapists may now use standardized clinical assessments, although patient-completed questionnaires remain the preferred method.
- Quality #281: Dementia: Cognitive Assessment
- This measure now requires a confirmed dementia diagnosis before administering a cognitive assessment, ensuring that assessments are appropriately targeted.
- Quality #282: Dementia Functional Status Assessment
- Speech-language pathologists (SLPs) are now included in this measure, recognizing their role in assessing changes in functional status for dementia patients.
- Quality #286: Dementia: Safety Concern Screening and Follow-Up for Patients with Dementia
- This measure has been expanded to include SLPs as practitioners capable of identifying and treating safety concerns in dementia patients.
- Quality #288: Dementia: Education and Support of Caregivers for Patients with Dementia
- Physical therapists and SLPs are recognized for their role in educating caregivers about dementia, ensuring a holistic approach to patient and caregiver support.
- Quality #281: Assessment of Cognitive Impairment or Dysfunction for Patients with Parkinson’s Disease (PD)
- Physical and occupational therapists are now included in the assessment for cognitive impairment or dysfunction in patients with Parkinson’s, ensuring that appropriate interventions are provided during the performance period.
- Quality #293: Rehabilitative Therapy Referral for Patients with Parkinson’s Disease
- This measure encourages referral loops for patients with Parkinson’s Disease, adding physical, occupational, and speech therapy to the list of disciplines involved in patient care.
- Quality #498: Connection to Community Service Provider Category
- This process measure ensures that physical and occupational therapists report on patients aged 18 or older who screen positive for social needs like food insecurity or housing instability and have connected with a community service provider within 60 days.
Updated Outcome Measures:
- Quality #503: Gains in Patient Activation Measure (PAM®) Scores at 12 Months
- CMS proposes lowering the minimum performance threshold and reducing the required time frame for re-administration of the PAM® surveys, lightening the burden on clinicians while still capturing important patient outcome data.
Enhancing Musculoskeletal Care Through MIPS Value Pathways
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:
New Quality Measures for Musculoskeletal Care:
- Q050: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older
- This measure ensures that physical therapists develop and document care plans for elderly women experiencing urinary incontinence, a common yet often under-addressed issue in this population.
- MSK6: Pain Improvement in Patients with a Neck Injury
- This measure tracks the percentage of patients with neck injuries who report an improvement in pain levels, emphasizing the importance of pain management in physical therapy.
- MSK7: Pain Improvement in Patients with Upper Extremity Injuries
- This measure assesses pain reduction in patients with upper extremity injuries, which is critical for evaluating the effectiveness of physical therapy interventions.
- MSK8: Pain Improvement in Patients with Back Injuries
- For patients with back injuries, this measure highlights the role physical therapists play in reducing pain and improving functional mobility.
- MSK9: Pain Improvement in Patients with Lower Extremity Injuries
- Tracking pain improvement in lower extremity injuries ensures that physical therapists can measure their success in helping patients regain mobility and reduce discomfort.
New Improvement Activity:
- IA_ERP_6: COVID-19 Vaccine Achievement for Practice Staff
- This improvement activity encourages practices to ensure that their staff achieves high levels of COVID-19 vaccination, contributing to public health efforts and maintaining a safe treatment environment for patients.
Improvement Activities to Be Removed:
- IA_CC_1: Closing Referral Loop by Returning Specialist Reports
- CMS is proposing to remove this improvement activity, which required the return of specialist reports to referring clinicians. The removal streamlines documentation requirements without affecting the quality of care.
- IA_EPA_1: 24/7 Access to Medical Records
- This activity, which provided continuous access to patient medical records, is also being proposed for removal. However, most physical therapy practices will already have digital systems in place that offer this functionality, minimizing the impact of this removal.
- This activity, which provided continuous access to patient medical records, is also being proposed for removal. However, most physical therapy practices will already have digital systems in place that offer this functionality, minimizing the impact of this removal.
Streamlining the CMS Proposed Rule for Physical Therapy Practices
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:
1. Maximize the Use of New CPT Codes for Caregiver Training
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:
- Train your billing staff to understand and correctly apply CPT code 96202 when caregiver training is provided.
- Integrate caregiver training as part of your patient’s overall care plan, ensuring that these sessions are well-documented and in compliance with CMS requirements.
- Create specific caregiver training protocols and materials that can be used during sessions to standardize the process and improve efficiency.
2. Implement Telehealth Flexibilities for Remote Supervision
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:
- Invest in telehealth platforms that enable real-time video communication, ensuring that you meet the technology requirements for remote supervision.
- Schedule supervision sessions efficiently by leveraging virtual tools, especially for clinics in rural areas or with limited onsite staff.
- Train your team to ensure compliance with CMS direct supervision rules, making it clear when and how this type of supervision can be used.
3. Stay Ahead with MIPS Value Pathways for Musculoskeletal Care
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:
- Regularly track and document patient progress against the new musculoskeletal quality measures, such as improvements in pain for neck, back, and extremity injuries (MSK6 through MSK9).
- Utilize outcome assessment tools and patient surveys to gather data that can be used to report on these measures, improving your practice’s performance in MIPS.
- Encourage staff to participate in improvement activities, like the COVID-19 Vaccine Achievement for Practice Staff (IA_ERP_6), which can contribute positively to your overall MIPS score.
4. Update Your Practice’s Documentation and Process Measures
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:
- Review your existing documentation processes to ensure that they align with the requirements for the 2025 process measures.
- Implement templates and checklists for common quality measures like fall prevention plans, medication documentation, and dementia assessments to streamline the recording process.
- Regularly audit patient records to ensure that all required information is captured and that your documentation meets CMS standards.
5. Leverage Technology for Efficient Reporting and Compliance
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:
- Use integrated documentation systems to automatically track compliance with process measures like Quality #130 (medication documentation) and Quality #182 (functional outcome assessments).
- Implement telehealth tools that allow for real-time supervision and ensure you meet the requirements for CMS direct supervision without the need for physical presence.
- Utilize billing software that is updated with the new CPT codes, such as CPT 96202, to ensure accurate reimbursement for caregiver training and other new services.
How PtEverywhere Can Help You Implement the CMS Proposed Rule 2025
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:
- Automated Documentation: Streamlines process measure reporting, including updated measures like medication documentation and functional outcome assessments.
- Telehealth Integration: Provides real-time audio-video supervision capabilities to meet CMS direct supervision requirements.
- Billing Optimization: Ensures your practice is compliant with new billing codes such as CPT 96202 for caregiver training.
- Compliance Tools: Tracks quality measures and improvements, helping you stay ahead in MIPS Value Pathways and maintain compliance with CMS updates.
- Efficient Workflow Management: Integrates scheduling, patient management, and documentation to streamline your daily operations, ensuring a smooth adaptation to 2025 rules.
PtEverywhere offers a robust platform to navigate these changes with ease, helping your practice stay compliant and efficient.
Preparing Your Physical Therapy Practice for 2025
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.