On Sept. 10, the Medicare Administrative Contractor Noridian Healthcare Solutions amended its existing guidance on the regulations governing certification of the therapy plan of care. The change, which updates the guidance to reflect the new POC signature exception, comes in response to outreach and a letter written by APTA in coordination with the American Occupational Therapy Association.
Noridian's updated resource includes specific language recommended in the letter and appeared less than a week following APTA's targeted outreach. The effort was part of APTA's ongoing advocacy urging more accurate and current guidance reflecting the Medicare plan of care signature exception that went into effect Jan. 1, under the Medicare Physician Fee Schedule rule, and which significantly decreased administrative burden and increased access to care. APTA has indicated to CMS and its contractors the importance of having clear and accurate guidance to ensure physical therapists are aware of the change and the reduced burden offered through the policy.
In the letter, APTA urged Noridian to update its guidance on the plan of care signature exception, which functionally modifies the standard for initial certification as it relates to physical and occupational therapy care under a referral.
The exception, effective Jan. 1, 2025, allows a signed and dated order or referral to meet the initial certification requirements as long as the order is in the patient’s medical record and there is evidence that the plan of care was submitted to the referring provider within 30 days of the initial evaluation. Once the PT has transmitted their plan, the onus is on the referring provider to either sign and return the POC or indicate changes; absent either action, silence serves as meeting the signature requirement for the transmitted POC.
Additionally, APTA called attention to how the updated certification requirement considerably reduces administrative burden, as time previously spent tracking physician signatures, which were needed to receive payment, can be replaced in certain circumstances simply by transmitting the POC one time and documenting transmission in the patient’s medical record. Communicating these updates effectively is a critical step in keeping providers from operating under outdated standards.
"APTA advised Noridian that updating its resources to reflect the requirements set forth in current regulation was crucial, given that the exception had been available for nearly nine months and the information outlining the requirement on their webpage was dated and no longer accurate," said APTA Director of Health Policy and Payment Sharon L. West, JD. "We are pleased that Noridian worked expediently to update this important information."
APTA will continue to work to ensure that policy information impacting the profession is up to date and accurately represented. Learn more about advocacy wins and stay up to date with the latest opportunities by joining the APTA Advocacy Network.
For questions or additional information please contact advocacy@apta.org.