Final 2024 Physician Fee Schedule: Supervision Changes Signal New Opportunities for Private Practices

Fee Schedule for Physical Therapy Reveals 2024 Is a Big Year for Supervision

The 2024 Physician Fee Schedule has some downsides for private practices, but there are also positive changes aimed at physical and occupational therapy providers. Organizations should examine these changes closely and consider how these updates can impact their operations this year. 

One of those areas is supervision, as CMS discussed supervision in three ways in the final rule, hinting at the potential for bigger changes in future rule-making. Let’s dig into what CMS said in the rule and how your practice can take advantage of these changes in 2024. 

General Supervision Carve-Out for Remote Therapeutic Monitoring

The biggest win for supervision this year was for remote therapeutic monitoring (RTM). CMS states in the final rule that physical and occupational therapists in private practice (PTPPs and OTPPs) have experienced significant challenges billing for monitoring services provided by assistant staff due to the limitations of supervision rules for Medicare Part B. CMS stated:

“These regulations make it difficult for physical therapists in private practice (PTPPs) and occupational therapists in private practice (OTPPs) to bill for the RTM services performed by the physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) they are supervising since the PTPP or OTPP must remain immediately available when providing direct supervision of PTAs and OTAs (even though we noted in the CY 2022 PFS final rule that PTPPs and OTPPs were intended to be among the primary billers of RTM services (86 FR 65116)).” (pg 494)

As a remedy to this challenge, they extended general supervision to enrolled PTs and OTs for the provision of RTM services only. CMS stated:

“[…] an RTM-specific general supervision policy at §§ 410.59(a)(3)(ii) and (c)(2) and 410.60(a)(3)(ii) and (c)(2) to allow OTPPs and PTPPs to provide general supervision only for RTM services furnished by their OTAs and PTAs, respectively.” (pg 495)

Continuation of Virtual Direct Supervision Through 2024

A helpful flexibility granted at the beginning of the PHE, virtual direct supervision was a convenient way for CMS to temporarily extend the principles of general supervision to private practice without requiring permanent changes. General supervision allows a supervising provider to be located in another facility as long as they are available by phone. Similarly, virtual direct supervision temporarily modified the definition of direct supervision to include immediate availability through telephone or video call. CMS stated:

“[…] we will continue to define direct supervision to permit the presence and immediate availability of the supervising practitioner through real-time audio and video interactive telecommunications through December 31, 2024. We believe that extending this definition of direct supervision through December 31, 2024 aligns the timeframe of this policy with many of the previously discussed PHE-related telehealth policies that were extended under provisions of the CAA, 2023.”

While CMS clearly stated the ending of this temporary PHE-related modification, there is continued discussion in the final rule indicating CMS wants to hear more from physical therapy and occupational therapy providers about extending general supervision beyond RTM, to all therapy services provided in private practice. 

The Future of General Supervision in Private Practice

The prospect of general supervision in private practice is exciting, and opens up many opportunities for organizations of all sizes. Allowing for more flexibility around supervision rules, organizations can develop practice models which take advantage of the ability to scale and specialize services by leveraging assistant staff more efficiently. 

Advocacy Is Needed

Advocacy around supervision kicked into high gear in 2023, and we should expect that 2024 will be no different. The APTA has released a position paper on supervision of PTAs, which calls out the inconsistency in the rules across settings and the benefits to access of rehabilitation services from extending general supervision to private practice. The APTA and the APTQI have both done extensive advocacy around the topic and have campaigns you can join to contact your lawmakers. We recommend adding your voice to this issue in 2024. 

Opportunities in 2024

Digital care and remote therapeutic monitoring should be at the top of every organization’s goals for 2024. Organizations that are new to digital care should provide education to their clinicians and consider piloting a solution before widespread implementation. Organizations that are ready to scale up their existing digital care initiatives may wish to consider incorporating PTAs in a centralized model now that CMS has clarified this general supervision carve-out for RTM, to increase efficiency of providing the service and increasing access for patients who would benefit from monitoring.

But no matter your level of digital care experience, partnering with an experienced vendor that has previously helped organizations develop their own digital services is the key to realizing the benefits for your practice and your patients. 

Learn more about the benefits of a centralized model in our upcoming webinar, Strategies to Incorporate Digital Care Into Your Practice in 2024: A Discussion with APTA. Register today to save your seat for this January 24th presentation and Q&A.

Another great resource is our featured white paper Centralized Digital Case Management: A New Model to Boost Therapeutic Alliance by digital care expert Anang Chokshi, PT, DPT, OCS, SCS.