Title: Correct Application Of Modifier CQ And CO
1 Correct Application Of Modifier CQ And
CO
2Correct Application Of Modifier CQ And CO
- CMS has established two modifiers, CQ and CO, to
indicate services furnished in whole or in part
by a physical therapist assistant (PTAs) or
occupational therapy assistants (OTAs),
respectively. The modifiers are defined as
follows - CQ modifier Outpatient physical therapy services
furnished in whole or in part by a physical
therapist assistant - CO modifier Outpatient occupational therapy
services furnished in whole or in part by an
occupational therapy assistant - Effective for claims with dates of service on and
after January 1, 2020, the CQ and CO modifiers
are required to be used, when applicable, for
services furnished in whole or in part by a
physical therapist assistant (PTAs) or
occupational therapy assistants (OTAs), on the
claim line of the service, along with the
respective GP or GO therapy modifier, to identify
those services furnished in whole or in part by a
PTA or OTA under a physical therapy or
occupational therapy plan of care. - These modifiers are required to be used for
therapy services furnished by providers that
submit institutional claims, including the
provider types outpatient hospitals,
rehabilitation agencies, skilled nursing
facilities, home health agencies and
comprehensive outpatient rehabilitation
facilities (CORFs). However, the CQ and CO
modifiers are not applicable to claims from
critical access hospitals or other providers that
are not paid for outpatient therapy services
under the PFS or section 1834(k) of the Act. The
CQ modifier must be reported with the GP therapy
modifier and the CO modifier with the GO therapy
modifier. Claims with modifiers not so paired
will be rejected/returned as unprocessable.
3Correct Application Of Modifier CQ And CO
Correct Application of Modifier CQ and CO Step 1
Identify the 15-minute timed HCPCS/CPT codes List
the code numbers of each of the services
furnished along with the number of minutes in
total done by the PT, PTA, OT, or OTA. When a
PT, PTA, OT, or OTA provides at least 15 minutes
and less than 30 minutes of a service on a single
treatment day, assign 1 unit when multiples of
15 minutes are furnished, e.g., 30 minutes
(assign 2 units) and 45 minutes (assign 3 units),
etc. This needs to be the first step whenever it
is applicable to the billing scenario. When any
of these services, i.e., full 15-minute
increments, are provided by PTAs/OTAs, the CQ/CO
modifiers apply. Applying the 8-minute
rule After applying Step 1, where it is
applicable, identify any minutes (including
remaining minutes from Step 1) performed by a
PT/OT and PTA/OTA for the same service/code. If
determining whether the CQ/CO modifier is
applicable for the final 15-minute unit, check to
see if the PT/OT furnished 8 minutes or more of
that last unit. If so, the last unit is billed
without the CQ/CO modifier because the PT/OT
provided enough minutes on their own to satisfy
the Medicare billing criterion for an exception
to the de minimis policy. Once the PT/OT meets or
exceeds the 8-minute mark, for the final unit in
a billing scenario, it does not matter how many
minutes the PTA/OTA furnishes for the same
service/code, that final unit is billed without a
CQ/CO assistant modifier. In these cases, any
minutes that the PTA/OTA furnishes for the final
unit would not matter for purposes of billing
Medicare. After applying Step 1, where it is
applicable, and determining the final unit of a
billing scenario, compare the minutes for the
same 15-minute service/code provided by the PT
and PTA (or the OT and OTA). Here are 2 times
the de minimis policy is applicable to that final
15-minute unit
4Correct Application Of Modifier CQ And CO
- Applying the De Minimis Standard Policy Cases
When the CQ/CO Modifier is Applied to Services
Defined by 15-minute Increments. - When the PTA/OTA furnishes 8 minutes or more of a
service and the PT/OT provides less than 8
minutes of the same service. - When both the PTA/OTA and the PT/OT each furnish
less than eight minutes for the final 15-minute
unit of a billing scenario. - Applying the De Minimis Standard Policy Cases
When the CQ/CO Modifier is Applied to Untimed
HCPSC/CPT Codes that Can Only be Billed with One
Unit. - The de minimis policy is applicable when the PT
and the PTA or the OT and the OTA each
independently provide minutes of the same untimed
service, including supervised modalities,
evaluations and re-evaluations, group therapy,
and certain RTM codes. In these cases, either the
simple or percentage method can be used to
determine if the PTA/OTA furnished more than 10
percent of the service. If so, the CQ/CO
modifier is appended to the claim for that unit
of service. - Instances where there are two 15-minute remaining
units left to bill and the PT/OT and PTA/OTA each
provide between 9 and 14 minutes with a total
time of at least 23 minutes and no more than 28
minutes.
5Correct Application Of Modifier CQ And CO
This finalized policy applies in a limited number
of cases where there are two 15-minute units of
therapy remaining to be billed for the same
service. For these limited cases, we are
allowing one 15-minute unit to be billed with the
CQ/CO modifier and one 15-minute unit to be
billed without the CQ/CO modifier in billing
scenarios where there are two 15-minute units
left to bill when the PT/OT and the PTA/OTA each
provide between 9 and 14 minutes of the same
service when the total time is at least 23
minutes and no more than 28 minutes. Billing for
the service with the most time After applying
Step 1 for each service and determining there is
only one unit left to bill, compare the remaining
minutes furnished by the PT/OT for the one
service with the remaining minutes furnished by
the PTA/OTA for the different service. Bill for
the service that took the most time. That is,
assign the CQ/CO modifier to the service provided
by the PTA/OTA when the time he/she spent is
greater than the time spent by the PT/OT
performing the different service. The CQ/CO
modifier does not apply when the minutes spent
delivering a service by the PT/OT are greater
than the minutes spent by the PT/OTA delivering a
different service.
6Correct Application Of Modifier CQ And CO
Tie-Breaker You have to identify the different
HCPCS/CPT codes where the PT/OT and the PTA/OTA
each independently furnish the same number of
minutes. Once Step 1 is completed for each
service (when applicable) and determining there
is only one unit left to bill, the remaining
minutes for each service, one provided by the
PT/OT and the other provided by the PTA/OTA, are
the same, either service may be billed, but not
both. If the service provided by the PT/OT is
billed, the CQ/CO modifier does not apply.
However, if the service provided by the PTA/OTA
is billed, the CQ/CO modifier does apply We
shared excerpt from section 20 of Medicare Claims
Processing Manual (MCPM)- Chapter 5 for reference
only, you can refer manual for detailed
information. Medisys Data Solutions is a leading
medical billing company providing complete
billing and coding services for various medical
billing specialities. If you need any assistance
in occupational and physical therapy billing,
contact us at info_at_medisysdata.com / 302-261-9187
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