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CO/CQ Modifiers Workflow

Since January 1, 2020, CMS requires modifiers to be applied to services provided by a PTA or OTA for patients with Medicare as the primary or secondary insurance. These modifiers, CQ and CO respectively, should be applied to any service where 10% or more was provided by the assistant. 

  • CQ modifier: Services furnished in whole or in part by a PTA
  • CO modifier: Services furnished in whole or in part by a OTA

Important: The availability of these modifiers is enabled for Medicare-type insurances by default. For all other insurances, this feature must be enabled manually by selecting Apply Therapist Assistant Modifiers (CO/CQ) in the payer’s Insurance Settings. For more information, please see Insurance Settings in WebPT.

To comply with CMS 2022  rules around Assistant Modifiers, the WebPT EMR can now identify both therapist and assistant contributions for each CPT code. The WebPT EMR will then use the minutes you provide to auto-calculate which units should have the Assistant Modifier, and which should not. This CO/CQ Modifier feature will not be present for dates of service prior to January 1st, 2022. For members using SOAP 1.0 click here for additional details regarding how to apply assistant modifiers. For members using SOAP 2.0 click here for details regarding Splitting CPT Codes between Therapists and Assistants.

Let’s review how these modifiers are added to your documentation. 

Scenario 1: Assistant Forwarding a Note

  1. A PTA (or OTA) begins a note in the WebPT EMR and enters charges for the services provided.
    Note: The appropriate modifier based on the user type automatically populates in the Modifier section and cannot be removed by the assistant.
  2. The PTA or OTA will forward the note to a supervising therapist by using the (...) button to select Forward.
  3. Select the supervising therapist from the drop-down, then click Apply.
  4. Next, the supervising therapist will open the note by navigating to the Incomplete Cosign Documents in the "At a Glance" alerts section of the Dashboard.
  5. From the Incomplete Cosign Documents table, select the note needing to be co-signed.
  6. The supervising therapist will see the CO or CQ modifier listed next to each code added by the assistant. The therapist has a few options here: 
    1. If any of the services were done in full by a PT or OT (greater than 90% of the service), you can click on the Modifier and uncheck it in the drop-down to remove it from that CPT® Code.
    2. You can also choose to split out the time spent on a CPT® Code by including it twice and differentiating the time that was spent by the assistant and the therapist. Simply add the code again using the CPT® Code + link and include treatment time. You’ll notice that no assistant modifiers are added to that charge line.

Note: If a charge is added in an addendum to this note by a PT or OT, the modifier will not be automatically applied. The CO/CQ modifiers will be available for selection as needed.

Scenario 2: Assistant Finalizing a Note

If you have enabled the ability for an assistant to finalize notes, the CQ or CO modifier will be automatically added to all CPT® Codes.

I bill Medicare Part A, do I need to use the CQ and CO modifiers?

If you bill Medicare Part A for your services (e.g., rehab agencies, CORFs), you will need to use the CQ/CO modifiers for any services furnished by a PTA or OTA. The requirement applies to payments for physical and occupational therapy in private practice, outpatient hospitals, rehab agencies, skilled nursing facilities, home health agencies, and comprehensive outpatient rehab facilities.

Billing Part A for outpatient therapy services does not exempt the practice from this requirement as payment is still made on the Part B physician fee schedule.

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