Impact of Medicare Physician Fee Schedule on OT Reimbursement Rates

Dr.Alex Carter
April 8, 2025
5 min read
reimbursement rates

Table of Contents

As a physical therapist or clinician, you're likely aware of the complex world of Medicare reimbursement. The Medicare Physician Fee Schedule (MPFS) directly affects compensating occupational therapy (OT) services. 

In recent years, updates to this schedule have raised important questions for healthcare providers. The impact of the Medicare Physician Fee Schedule on OT reimbursement rates is profound and requires close attention to ensure that your practice continues to operate efficiently.

With the start of 2025, there are new changes to the Medicare Physician Fee Schedule, which will affect reimbursement rates, payment structures, and administrative requirements for occupational therapists.

In this blog, we will break down the 2025 updates, how they impact OT reimbursement rates, and how you can best adapt to these changes in your practice.   

Latest Medicare Fee Schedule Updates 2025

The Medicare Physician Fee Schedule (MPFS) details the payment rates and policies that apply to services provided by physicians and non-physician practitioners, including occupational therapists, under Medicare Part B. Starting January 1, 2025, there are significant updates that will affect reimbursement rates and therapy services.

Here are some of the key updates to the Medicare Physician Fee Schedule (MPFS) for 2025:

  • Revised Payment Rates
  • Telehealth Services Expansion
  • Chronic Care Management (CCM)
  • Physical Therapy and Occupational Therapy
  • New Codes for Behavioral Health
  • Value-based Payment Modifications
  • Medicare Advantage Payment Reforms
  • New Procedures and Services
  • Adjustment of Payment for Surgical Services

Payment and Conversion Rates for 2025

For 2025, one of the key updates to the Medicare Physician Fee Schedule is the adjustment of payment rates and the conversion factor. The conversion factor, which is the dollar amount applied to each Relative Value Unit (RVU) to calculate payment for services, has seen a slight decrease. This decrease will have a direct impact on reimbursement for a wide range of services, including OT.

Year Conversion Factor
2024 $33.29
2025 $32.35

This reduction in the conversion factor results in a lower payment for many healthcare services provided under Medicare. In addition to the conversion factor changes, budget neutrality adjustments are also influencing the fee schedule for 2025. 

Medicare must ensure that its overall spending on physician services does not exceed a predetermined budget, leading to adjustments across different service categories.

With these changes in mind, it’s important to examine how they will impact OT services specifically.

What is the Impact of the Medicare Fee Schedule on Occupational Therapy?

After the implementation of the Medicare Fee Schedule changes, OT practitioners and clinic owners need to stay informed and actively participate in advocacy efforts. This helps in ensuring sustainable practice operations and access to care for patients.

What is the Change in OT Reimbursement Rate?

Occupational therapy practitioners are likely to experience a reduction in payment rates due to a decrease in the conversion factor, representing a 2.93% cut in 2025. This reduction is part of a broader trend of budget neutrality adjustments that aim to balance Medicare spending across various services.

In addition to the conversion factor cut, there will be changes to the therapy threshold, which is now set at $2,410, an increase from the previous threshold of $2,330 in 2024. This threshold applies to both physical therapy and occupational therapy services combined. Once services exceed this amount, you can continue billing by using the KX modifier, provided you document medical necessity. 

How does this affect OT Practitioners with Medicare Part B?

The changes outlined in the MPFS pose several challenges for OT practitioners, and understanding them helps maintain effective practice and ensure compliance.

  • Reduced Revenue: The decrease in reimbursement rates directly impacts the financial viability of practices, making it harder for you to maintain service levels and staff.
  • Increased Administrative Burden: While some administrative processes are being streamlined, you will still face challenges related to documentation and compliance with new billing requirements. But platforms like SpryPT can help you in those times with integrated billing and faster reimbursements.
  • Access to Care Concerns: Reduced reimbursement may lead to fewer available services for Medicare beneficiaries, impacting patient access to necessary therapies.

If you are looking for a better understanding of this, watch this video by Amplify OT to learn more about how the Medicare Fee Schedule impacts OT:

Amplify OT

While the new fee schedule presents challenges, advocacy from the American Occupational Therapy Association (AOTA) has driven positive changes. Here’s a look at the benefits of AOTA’s ongoing efforts.

Benefits from AOTA Advocacy

The intervention by the AOTA has resulted in the following developments:

  • New CPT Codes for Telehealth Services

AOTA has successfully lobbied for the inclusion of new CPT codes for telehealth services, allowing greater flexibility in delivering care remotely.

  • Changes to Supervision Requirements

Changes in supervision requirements mean that occupational therapy assistants (OTAs) can now work under general supervision, which may help you optimize staffing models and improve service delivery.

  • Ongoing Advocacy Against Payment Cuts

AOTA continues to advocate against cuts and seeks legislative support to stabilize payment rates, emphasizing the importance of fair reimbursement for quality care delivery.

  • Support for Legislative Actions to Protect OT

Advocating for legislation that protects and supports the field of OT. This includes fighting for legislative measures that would block further cuts, push for increased funding, and advocate for policies that enhance access to care.

  • Improved Access to Medicare Benefits

Through continuous lobbying efforts, AOTA works to ensure that Medicare beneficiaries have improved access to essential OT services.

AOTA advocates for fair Medicare reimbursement and the value of OT services by engaging with policymakers, educating stakeholders, and empowering members through grassroots initiatives to influence healthcare policy.

Maximize your clinic's revenue with SpryPT's integrated billing solutions. Contact us to see how we can streamline your reimbursement process!

With these updates and challenges, it’s useful for you to explore the various reimbursement models that exist under Medicare. Read on to learn about them. 

Reimbursement Models in OT Under Medicare

Understanding the reimbursement models under Medicare is essential. The Medicare system employs various payment structures that impact how services are billed and reimbursed. Here, we will discuss three primary models: Fee-For-Service, Capitated Payments, and Bundled Payments.

1. Fee-for-Service: Volume-Based Model

The Fee-For-Service (FFS) model is the traditional approach used in outpatient therapy settings under Medicare Part B. In this model, you receive payment for each service rendered to a patient. This means that the more services you deliver, the higher the reimbursement.

However, this volume-based model has its downsides. It may incentivize unnecessary procedures since you are paid for every individual service. For instance, occupational therapy services are billed using Current Procedural Terminology (CPT) codes, which can vary in value based on the complexity and duration of the service provided. 

Providers must adhere to guidelines like the 8-minute rule, which dictates how time spent on therapy translates into billable units. According to this rule, you can only bill for a unit of service if you provide at least eight minutes of direct patient contact. Billing increments typically occur in 15-minute units. For instance:

  • If you spend 8 to 22 minutes with a patient, you can bill for one unit.
  • For 23 to 37 minutes, you can bill for two units.
  • This pattern continues, allowing up to six units for longer sessions.

Understanding and applying this rule accurately helps ensure compliance with Medicare guidelines and maximizes potential reimbursement without risking overbilling or underbilling.

The FFS model can lead to financial uncertainty as your income depends heavily on patient volume. As a result, it can create pressure to increase service delivery, potentially impacting the quality of care.

How to Prevent Overcharging in the Fee-for-Service Model?

While the fee-for-service model allows flexibility in billing, it also raises concerns about overcharging. To prevent this, you should adhere strictly to ethical billing practices. This includes:

  • Conducting thorough evaluations to determine the necessity of each service.
  • Ensuring that every billed service corresponds directly to documented care provided.
  • Educating staff on proper billing procedures and maintaining accurate records of treatment times.

By focusing on necessary services and ethical billing practices, you can maintain trust with your patients while also contributing to a more sustainable healthcare system.

2. Capitated Payments: Value-Based Model

In contrast to FFS, capitated payments represent a value-based reimbursement model. Under this system, you receive a fixed payment per patient for a designated period, regardless of how many services that patient requires. This approach is akin to a gym membership, where the provider gets paid monthly whether or not the patient utilizes services extensively.

  • Quality Over Quantity: With capitated payments, you are incentivized to deliver high-quality care that promotes patient health. This approach leads to better preventive care outcomes as you are motivated to keep patients healthy rather than relying on frequent visits for treatment.
  • Cost Control: By receiving a set fee per patient, you can manage the resources more effectively. This model reduces the financial incentive to perform unnecessary procedures, which can help control overall healthcare costs. Studies have shown that capitation can be more cost-effective compared to fee-for-service models, particularly for managing chronic conditions.
  • Holistic Care: Capitation supports a more integrated approach to patient care. You can collaborate with other healthcare providers to address multiple aspects of a patient's health. You are able to provide a comprehensive treatment that aligns with the patient's needs and goals. However, it also places financial risk on you if patients require extensive care within the payment period.

3. Bundled Payments: Value-Based Model

Bundled payments represent another innovative approach to value-based care. This model provides a single payment that covers all services related to a specific episode of care—such as surgery or rehabilitation—over a defined time frame. Unlike FFS, where each service is billed separately, bundled payments encourage coordination among various healthcare providers involved in a patient's treatment.

Bundled payments represent another shift in reimbursement strategies. This is evident with the implementation of the Patient-Driven Groupings Model (PDGM) for home health services and the Patient-Driven Payment Model (PDPM) for skilled nursing facilities.

  • Patient-Centered Focus: Both PDGM and PDPM prioritize patient outcomes over service volume. Under these models, reimbursement is based on the patient's clinical characteristics and care needs rather than the number of therapy minutes or visits. This change encourages you to focus on achieving functional improvements in your patients.
  • Financial Dynamics: The introduction of bundled payments has altered the financial dynamics of therapy services. While these models can limit revenue generation from traditional therapy sessions, they also provide opportunities for OTs to demonstrate value through improved patient outcomes. 
  • Challenges and Opportunities: The transition to bundled payment models has not been without challenges. Some OTs report job insecurity and reduced hours as facilities adjust to these new payment structures. However, those who adapt by enhancing their skills in patient assessment and outcome measurement can find new opportunities in this evolving environment.

However, careful management is required to ensure that all parties involved provide the necessary services without compromising quality.  

Implications of Medicare Policy Changes

Implications of Medicare Policy Changes

The recent updates to the MPFS bring several implications for healthcare providers, particularly in the fields of telehealth, care for older adults, and coding and billing practices. Here’s a closer look at these areas.

1. Telehealth and Virtual Services

The important updates to telehealth services aim to improve access to care while addressing the evolving needs of patients and providers.

  • Emphasis on Telehealth: The 2025 MPFS continues to support telehealth, allowing providers to reach patients remotely, particularly older adults with mobility issues.
  • Expanded Coverage: CMS has broadened coverage for telehealth services, enhancing access to care.
  • Financial Considerations: Reimbursement rates for telehealth mirror those of in-person services, necessitating careful financial planning for practices integrating telehealth.

Check out SpryPT’s reimbursement calculator to learn about your estimated reimbursement for the services you provide!

2. Older Adults and Their Care

The 2025 MPFS updates aim to improve healthcare access and quality for older adults, addressing financial concerns while enhancing care.

  • Impact on Access: Reduced reimbursement rates may discourage providers from accepting new Medicare patients, leading to longer wait times and fewer therapy options.
  • Increased Therapy Threshold: The therapy threshold rises from $2,330 to $2,410, requiring justification for higher service levels and encouraging more comprehensive treatment strategies.
  • Concerns in Underserved Areas: The potential decrease in provider participation worsens access to care in rural and underserved areas, highlighting the need for solutions to ensure adequate coverage.

3. Coding and Billing Adjustments

The 2025 MPFS coding and billing adjustments simplify the billing process while enhancing the accuracy of claims.

  • Streamlined Certification Process: A signed physician order or referral now meets plan of care certification, reducing administrative tasks and allowing more focus on patient care.
  • Importance of Accurate Coding: Accurate coding promotes compliance, faster reimbursements, and maintaining high-quality care.
  • Investment in Training: Clinics should invest in staff training and technology solutions to ensure billing accuracy and improve financial health and service delivery.

4. OTA Supervision in Private Practice

The supervision of OTAs in private practice settings has undergone important changes, particularly in light of recent Medicare policy updates. Here are the key points regarding OTA supervision:

  • General supervision of OTAs is now allowed by occupational therapists.
  • This change enhances flexibility in service delivery, particularly in rural or underserved areas.
  • OTs can allocate resources more effectively while maintaining high-quality patient care.

Suggested read: Top 50 Occupational Therapy Acronyms & Abbreviations

5. Caregiver Training

Caregiver training is an essential component of patient care, particularly for individuals with chronic illnesses or disabilities. Recent updates to Medicare policies have made caregiver training services more accessible and structured.

  • Emphasis on caregiver training as part of the therapy process.
  • Encourages OTs to actively engage caregivers in treatment plans.
  • Improves patient outcomes and fosters a collaborative environment.
  • Caregivers gain skills and knowledge to support their loved ones effectively.

6. Eliminating the Physician’s Signature Requirement on Care Plans

An important aspect of the recent legislative changes is the proposal to eliminate the requirement for a physician's signature on care plans.

  • Simplifies administrative processes and grants OTs greater autonomy.
  • Allows for quicker responses to patient needs and timely adjustments to treatment strategies.
  • Streamlines workflows, enabling therapists to focus more on patient care.

7. Merit-based Incentive Payment System (MIPS)

The Merit-based Incentive Payment System (MIPS) continues to play a crucial role in determining reimbursement rates for therapy services under Medicare. MIPS incentivizes providers based on their performance across various quality measures, including patient satisfaction and clinical outcomes. 

Stay ahead of Medicare fee schedule changes with SpryPT. Our platform automatically updates to keep you compliant. Learn more about our adaptive features. Check our pricing page for more information.

Medicare policies evolve to prioritize outcomes over volume. Therefore, understanding the shift towards quality and value-based care will help you in the long run. Let’s explore how the MPFS changes impact service delivery and patient outcomes.

Quality and Value-Based Care

The focus of the Medicare Physician Fee Schedule (MPFS) is shifting towards quality rather than merely the quantity of care provided. This change reflects a broader trend in healthcare aiming to improve patient outcomes and ensure that patients receive meaningful services.

  • Focus on Quality Over Quantity of Care

In the past, reimbursement models incentivized higher service volumes regardless of effectiveness. Now, MPFS encourages healthcare professionals to prioritize quality, rewarding better patient outcomes rather than just more treatments or appointments.

  • Emphasis on High-Value Services for Patients

MPFS emphasizes delivering high-value care, where treatments and interventions offer benefits relative to their costs. Services like preventive care, chronic disease management, and rehabilitation are prioritized.

Providers can assess service value through metrics like patient satisfaction, functional improvements, and health outcomes, ensuring care that meets patient needs without unnecessary procedures.  

As we wrap up, let’s look at the future challenges of OT reimbursement and the direction of policy changes. 

Future Challenges and Opportunities in OT Reimbursement

The landscape of OT reimbursement is evolving, presenting both challenges and opportunities for practitioners. 

  • Streamlined Administrative Processes: New provisions aim to reduce administrative burdens, particularly easing plan of care certification requirements. This change could improve efficiency and allow practitioners to focus more on patient care.
  • Legislative Support: The proposed Medicare Patient Access and Practice Stabilization Act seeks to eliminate the planned reduction and introduce an inflation adjustment, potentially providing an increase in the conversion factor. This could stabilize reimbursement rates for practices.
  • Impact on Access to Care: Continued cuts in reimbursement rates may lead to fewer providers accepting Medicare patients, particularly in rural and underserved areas, potentially reducing access to necessary OT services.
  • Advocacy Efforts: Organizations like AOTA are actively advocating for fair compensation and reimbursement rates. Their efforts are crucial in influencing policy changes that can benefit occupational therapy practitioners.
  • Financial Strategies for Practices: As reimbursement rates decline, practitioners may need to reassess their financial strategies, including adjusting fee schedules or exploring alternative revenue streams to maintain practice viability.

Conclusion

Navigating the evolving OT reimbursement rates and Medicare policy changes is crucial for providing high-quality care while maintaining financial sustainability. As the focus shifts to value-based care, staying informed and engaged in advocacy efforts will help ensure continued success in this changing landscape.

To streamline your practice and stay ahead of Medicare changes, enhance your OT services with SpryPT's customizable EMR

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