Effective January 1, 2025, CMS has updated the signed plan of care (POC) rule that a script can serve in lieu of a signed POC.
Rick Gawenda has written a great summary:
CMS finalized their proposal that if a Medicare beneficiary presents to physical therapy, occupational therapy, and/or speech therapy with an appropriate order that documents the type of therapy (PT, OT, or ST), is signed and dated by the physician, physician assistant (PA), nurse practitioner (NP), or clinical nurse specialist (CNS), and the therapist has documented evidence that the plan of care has been delivered to the physician, NP, PA, or CNS within 30 days of completion of the initial evaluation, that this order will serve as the initial certification and a separate signed and dated plan of care by the physician, PA, NP, or CNS will not be required.
For cases with an Initial Evaluation date of January 1, 2025 and later
Due to this POC Compliance update, the Signed POC checklist item for Initial Evaluations will be marked as done if both of the following are present:
- a physician script has been uploaded to the patient’s case
- the POC has been successfully faxed.
This will also mark the signed POC as done on the POC report. A signed POC can still be uploaded to the patient’s case to mark the Signed POC checklist item as done.
All subsequent POC updates created by a Progress, Re-evaluation, or Re-Certification note will require a file to be uploaded and saved to the patient's case as a 'signed POC' to be marked as done in the chart and on the POC Report.
For cases with an Initial Evaluation date of December 31, 2024 and earlier
The case checklist and signed POC tracking will continue as they have, requiring a signed POC to be uploaded to the patient’s case in order to mark the Signed POC checklist item as done. An uploaded script will not impact the status of the signed POC.
For reference, here’s a link to Rick Gawenda’s article and here is Medicare’s Final Rule. The updates to physical therapy begin on page 542 with POC updates covered on page 555.
Medicare also published a summary with the sections “Certification of Therapy Plans of Treatment with a Physician or NPP Order” and “Supervision Policy for Physical Therapists (PTs) and Occupational Therapists (OTs) in Private Practice”.
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