Summary: The 2026 Physical Therapy Compliance changes introduce significant updates to Medicare documentation requirements, emphasizing enhanced medical necessity documentation, mandatory functional outcome integration, and stricter supervision documentation. Key actions for physical therapy practices include auditing current documentation practices, implementing outcome measurement protocols, and training staff on new standards. To ensure compliance and avoid substantial penalties, practices should consider using SPRY software, which offers an all-in-one solution for streamlined documentation and billing compliance.
2026 Physical Therapy Compliance: Essential Medicare Updates and Documentation Requirements
Are you prepared for the Medicare payment and regulatory changes affecting physical therapy practices in 2026?
The physical therapy compliance landscape for 2026 brings important updates to Medicare reimbursement rates, new remote monitoring opportunities, and continued emphasis on documentation excellence. With the CMS 2026 Medicare Physician Fee Schedule Final Rule now in effect and critical telehealth policy expirations, physical therapy practices must understand these changes to maintain compliant operations and optimize reimbursement.
The Centers for Medicare & Medicaid Services released its Calendar Year 2026 Medicare Physician Fee Schedule Final Rule on October 31, 2025, introducing the first positive conversion factor update in five years alongside new Remote Therapeutic Monitoring codes and important policy clarifications that impact physical therapy billing and documentation practices.
TL;DR: Essential 2026 Physical Therapy Compliance Changes
Critical Effective Date: January 1, 2026 - CMS 2026 Final Rule takes effect
Key Updates:
- First positive conversion factor increase in five years: 3.26% for non-APM participants
- New Remote Therapeutic Monitoring (RTM) codes expand reimbursement opportunities
- KX modifier threshold remains at $2,480 for PT/SLP services combined
- Critical: Physical therapist telehealth privileges EXPIRE January 31, 2026
- Efficiency adjustment (-2.5%) affects specific untimed codes
Immediate Action Items:
- Review billing practices for new RTM code implementation
- Prepare for telehealth service transition after January 31, 2026
- Verify documentation meets longstanding Medicare medical necessity standards
- Update staff training on 2026 payment changes and compliance requirements
- Assess impact of conversion factor changes on practice revenue
Financial Impact: The 3.26% conversion factor increase is offset by RVU adjustments, resulting in an estimated net -1% impact for most PT practices according to CMS projections.
Understanding the 2026 Medicare changes is essential for physical therapy practice sustainability. Medicare continues to emphasize proper documentation, medical necessity establishment, and compliance with longstanding billing requirements that remain critical for audit preparedness.
Question 1: What are the actual CMS payment changes for physical therapy in 2026?
The short answer: The 2026 Medicare Physician Fee Schedule includes the first positive conversion factor increase in five years, new RTM codes for musculoskeletal monitoring, and important clarifications on therapy service billing requirements.
2026 Conversion Factor Update
For the first time since 2020, CMS finalized an increase to the Medicare conversion factor:
Conversion Factor Rates:
- Non-qualifying APM participants: $33.4009 (3.26% increase from 2025)
- Qualifying APM participants: $33.5675 (3.77% increase from 2025)
- Medicare Economic Index (MEI): 2.7% for 2026
Important Context: While the conversion factor increased, CMS estimates a net -1% impact on physical therapy services due to relative value unit (RVU) adjustments that affect individual code reimbursement rates.
Source: CMS Medicare Physician Fee Schedule Final Rule (MM14315), October 31, 2025
New Remote Therapeutic Monitoring Codes
CMS finalized three new RTM codes effective January 1, 2026, designated as "sometimes therapy" services:
Device Supply Codes (2-15 days of data transmission):
- CPT 98984: Respiratory system monitoring - Average national rate: $47.00
- CPT 98985: Musculoskeletal system monitoring - Average national rate: $40.00
Treatment Management Code:
- CPT 98979: First 10 minutes of treatment management services with at least one real-time interactive communication - Average national rate: $26.00
These codes complement existing 16-30 day RTM codes (98976, 98977) and provide new revenue opportunities for practices implementing remote patient monitoring for musculoskeletal conditions.
Key Billing Rules:
- Cannot bill both 2-15 day and 16-30 day device codes in same calendar month
- Treatment management codes require therapy plan of care when provided by therapists
- CQ/CO modifiers apply when furnished by therapy assistants
Source: CMS MLN Matters MM14250 - Therapy Code List: 2026 Annual Update
Efficiency Adjustment Impact
CMS finalized a -2.5% efficiency adjustment targeting non-time-based codes, using a five-year look-back period of MEI productivity adjustments.
Good News for Physical Therapy: Most PT codes are exempt from this adjustment because they are time-based (billed in 15-minute increments).
Affected Untimed Codes:
- 97014 (Electrical stimulation, unattended)
- 97010 (Hot/cold packs)
- 97012 (Mechanical traction)
Codes REMOVED from Efficiency Adjustment List (based on PT community advocacy):97032, 97033, 97034, 97035, 97036, 97113, 97124, 97140, 97533
Source: Alliance for Physical Therapy Quality and Innovation (APTQI) Final Rule Analysis, November 2025
Question 2: What are the 2026 KX modifier threshold requirements?
The short answer: The KX modifier threshold remains at $2,480 for combined physical therapy and speech-language pathology services, with the medical review threshold staying at $3,000 through 2028.
2026 KX Modifier Thresholds
The therapy threshold amounts for Calendar Year 2026 are:
- Physical Therapy and Speech-Language Pathology (combined): $2,480
- Occupational Therapy: $2,480
- Medical Record (MR) threshold for targeted medical review: $3,000
What This Means:When Medicare beneficiaries reach these annual threshold amounts, you must:
- Append the KX modifier to claim lines at and above the threshold
- Maintain documentation that services are medically necessary
- Document that patients require continued skilled therapy to achieve functional improvement
Important: The KX modifier is an attestation that documentation in the patient's medical record justifies the services. You do not need to submit special documentation with the KX modifier, but you must have defensible documentation available if audited.
Medical Review Threshold
Services exceeding $3,000 annually may be subject to targeted medical review by the Supplemental Medical Review Contractor (SMRC). This threshold remains at $3,000 through 2028, after which it will be indexed annually by the Medicare Economic Index.
Critical Point: Not all claims exceeding $3,000 are reviewed, but practices should ensure robust documentation for all services, particularly those approaching or exceeding the medical review threshold.
Sources:
- CMS Change Request 13437
- CMS Publication 100-04, Chapter 5, Section 10.2 and 10.3
- Noridian Medicare Administrative Contractor Guidance
Question 3: What is happening with physical therapy telehealth services in 2026?
The short answer: Physical therapist Medicare telehealth privileges are set to EXPIRE on January 31, 2026, unless Congress takes action to extend or permanently establish these flexibilities.
Critical Telehealth Timeline
Current Status (as of December 30, 2025):
- Temporary telehealth flexibilities extended through January 30, 2026
- Physical therapists, occupational therapists, speech-language pathologists, and audiologists can furnish Medicare telehealth services through this date
- Extension resulted from government shutdown resolution in November 2025
January 31, 2026 - CRITICAL DEADLINE: After January 30, 2026, physical therapists will no longer be able to furnish Medicare telehealth services unless Congress passes legislation to extend or permanently establish these privileges.
What This Means for Your Practice:
- You CAN bill for Medicare telehealth PT services through January 30, 2026
- After January 31, 2026, you CANNOT bill Medicare for PT telehealth services
- State practice acts still govern telehealth for non-Medicare patients
- Further extension requires congressional action
Permanent Telehealth Changes Finalized
While PT telehealth privileges expire, CMS finalized several permanent telehealth policies effective January 1, 2026:
Direct Supervision Definition:
- Permanently allows use of real-time audio and visual interactive telecommunications for direct supervision
- Applies to incident-to services, diagnostic tests, and rehabilitation services
- Excludes surgeries with 10- or 90-day global periods
Telehealth Originating Site Facility Fee:
- Updated to $31.85 for 2026 (based on 2.7% MEI increase)
Sources:
- CMS Telehealth FAQ for Calendar Year 2026 (updated November 14, 2025)
- APTA: "Government Shutdown Ended: Telehealth Flexibilities Extended Until Jan. 30, 2026" (November 17, 2025)
- CMS 2026 Medicare Physician Fee Schedule Final Rule
Advocacy Actions
APTA continues advocating for permanent telehealth access for physical therapists. If this issue is important to your practice:
- Contact your members of Congress through the APTA Patient Action Center
- Share patient impact stories demonstrating telehealth benefits
- Participate in advocacy campaigns as they are announced
Important Planning Note: Practices relying on Medicare telehealth revenue should develop contingency plans for potential service delivery changes after January 31, 2026.
Question 4: What documentation requirements must meet for Medicare physical therapy services?
The short answer: Medicare continues to require comprehensive documentation establishing medical necessity, demonstrating skilled service provision, documenting measurable functional goals, and correlating interventions with patient progress—requirements that have been longstanding Medicare policy.
Core Medicare Documentation Requirements
While CMS did not introduce new documentation standards in the 2026 Final Rule, existing Medicare documentation requirements remain critical for compliance and audit preparedness:
1. Medical Necessity Establishment
Your initial evaluation must establish that services are medically necessary by documenting:
- Objective impairments: Specific, measurable deficits affecting function
- Functional limitations: How impairments impact activities of daily living
- Skilled service need: Why licensed physical therapist expertise is required
CMS Definition of Medical Necessity: Healthcare services or supplies needed to prevent, diagnose, or treat an illness, injury, condition, disease, or its symptoms, and that meet accepted standards of medicine.
2. Skilled Service Justification
Documentation must differentiate skilled physical therapy services from:
- Maintenance therapy (sustaining current functional level)
- General exercise programs (no skilled intervention required)
- Activities patients can perform independently
Skilled Services Include:
- Initial assessment and periodic reassessment
- Design and modification of treatment programs
- Teaching complex therapeutic activities
3. Functional Goal Documentation
Establish measurable, achievable functional goals using objective criteria:
SMART Goal Framework:
- Specific: Clearly defined functional activity
- Measurable: Quantifiable outcome criteria
- Achievable: Realistic based on patient condition
Example: "Patient will independently ascend/descend 12 stairs with rail, without loss of balance, within 4 weeks to safely access second-floor bedroom."
Best Practice Tools for Outcome Measurement
While not CMS-mandated, validated assessment tools strengthen documentation:
Universal Assessment Tools:
- PROMIS Physical Function (computer adaptive testing)
- FOTO (Focus on Therapeutic Outcomes)
- AM-PAC Basic Mobility
Condition-Specific Tools:
- Oswestry Disability Index (low back pain)
- Neck Disability Index (cervical conditions)
- DASH/QuickDASH (upper extremity)
Sources:
- CMS Publication 100-04, Chapter 5 - Part B Outpatient Rehabilitation and CORF/OPT Services
- CMS Medicare Benefit Policy Manual, Chapter 15
- APTA Medicare Coding and Billing Guidelines
Question 5: How do I properly document and bill therapeutic activities (97530) and neuromuscular reeducation (97112)?
The short answer: Documentation must clearly establish the complexity, functional nature, and skilled intervention requirements that distinguish these services from lower-level therapeutic exercise, with specific clinical indicators documented at initial evaluation.
CPT 97530 - Therapeutic Activities Documentation
Code Definition: Therapeutic activities involve dynamic activities to improve functional performance with direct one-on-one patient contact.
Documentation Requirements:
1. Functional Activity Focus:
- Activities that directly simulate or relate to functional tasks
- Multi-component activities requiring coordination of multiple systems
- Real-life task simulation (e.g., lifting, carrying, reaching, bending)
2. Skilled Intervention Justification:
- Clinical decision-making required for activity progression
- Safety monitoring during dynamic movement
3. Complexity Differentiation: Document what makes activities complex enough to require skilled PT intervention versus simple exercise:
- Multi-planar movements with functional purpose
- Balance challenges during functional tasks
-
Example Documentation: "Patient performed therapeutic activities including simulated grocery shopping tasks: reaching overhead to upper shelves (shoulder flexion to 150°), carrying 10-lb weighted basket while ambulating 50 feet (bilateral UE coordination, dynamic balance), and squatting to lower shelves (hip/knee flexion with weight-bearing). Required skilled instruction for proper body mechanics, safety monitoring during dynamic movements, and activity progression based on patient response. Activity directly relates to patient's goal of independent grocery shopping."
CPT 97112 - Neuromuscular Reeducation Documentation
Code Definition: Therapeutic procedure to improve balance, coordination, kinesthetic sense, posture, and proprioception.
Clinical Indicators at Initial Evaluation:
Document at least one of these impairments with objective measures:
1. Balance Deficits:
- Berg Balance Scale score <45/56
- Timed Up and Go test >12 seconds
- Unable to maintain single-leg stance >5 seconds
- Abnormal functional reach test results
2. Proprioceptive Impairments:
- Joint position sense testing abnormalities
- Inability to reproduce joint positions without visual input
- Decreased awareness of body position in space
3. Movement Coordination Problems:
- Abnormal movement patterns during functional tasks
- Inability to perform smooth, coordinated movements
- Ataxia or dysmetria affecting function
Sources:
- CMS Medicare Claims Processing Manual, Chapter 5
- American Medical Association CPT Code Descriptions
- APTA Coding and Payment Resources
Question 6: What are the supervision requirements for physical therapist assistants in 2026?
The short answer: General supervision is now permitted for PTAs providing Medicare Part B outpatient services, meaning the supervising physical therapist does not need to be physically present but must be available for consultation.
Important 2025 Change Continuing in 2026
In 2025, CMS changed the supervision requirement for physical therapist assistants under Medicare Part B from direct supervision (physical presence) to general supervision, aligning outpatient settings with supervision policies in all other Medicare settings.
General Supervision Definition:The supervising physical therapist is not required to be physically present in the office but must be available by telecommunications to assist the PTA if needed.
What This Means:
- PTAs can treat Medicare patients without PT physically on-site
- Supervising PT must be available for consultation
Documentation Requirements
While general supervision is permitted, proper documentation remains essential:
1. Plan of Care Oversight:
- PT establishes initial evaluation and treatment plan
- PT determines which interventions can be delegated to PTA
- PT provides clear intervention guidance
2. Progress Assessment:
- PT conducts required reassessments per state practice act
- PT documents clinical decision-making for treatment modifications
- PT assesses patient progress and adjusts plan accordingly
3. Skilled Decision-Making:
- Document PT clinical judgment in treatment planning
- Show PT involvement in complex cases
- Demonstrate appropriate oversight of PTA interventions
4. Modifier Requirements:Use appropriate modifiers when PTA provides services:
- CQ modifier: Outpatient physical therapy services furnished by PTA
- CO modifier: Outpatient occupational therapy services furnished by OTA
State Practice Act Considerations
Important: Medicare supervision requirements establish the minimum standard, but state practice acts may require more stringent supervision. Always comply with the more restrictive requirement:
- Check your state physical therapy practice act
- Ensure compliance with state board regulations
- Verify supervision requirements in your jurisdiction
Sources:
- APTA: "APTA Public Policy Priorities, 2025-2026" (February 4, 2025)
- CMS 2025 Medicare Physician Fee Schedule Final Rule
- CMS Medicare Benefit Policy Manual, Chapter 15
Question 7: How do I document evaluation codes (97161-97163) appropriately?
The short answer: Evaluation complexity must be justified through documentation of clinical decision-making complexity, examination comprehensiveness, and patient presentation factors that support the specific evaluation level billed.
CPT 97161 - Physical Therapy Evaluation: Low Complexity
Appropriate When:
- Stable condition with minimal complicating factors
- Single body region or system involvement
- Straightforward clinical presentation
Documentation Elements:
- Chief complaint and history
- Examination of 1-2 body regions/systems
- Clinical impression and diagnosis
Typical Examples:
- Uncomplicated ankle sprain, young healthy patient
- Simple back strain without radicular symptoms
- Post-surgical knee, progressing as expected
CPT 97162 - Physical Therapy Evaluation: Moderate Complexity
Appropriate When:
- Evolving clinical presentation
- Multiple body regions or systems involved
Documentation Elements:
- Comprehensive history including comorbidities
- Examination of 2-3 body regions/systems with correlation
- Moderate complexity clinical decision-making
Typical Examples:
- Multiple joint involvement affecting function
- Condition with moderate comorbidities
- Patient requiring multidisciplinary coordination
Sources:
- American Medical Association CPT Code Descriptions
- CMS Medicare Claims Processing Manual
- APTA Evaluation and Assessment Resources
Question 8: What should I know about implementing Remote Therapeutic Monitoring (RTM) in my practice?
The short answer: The new 2026 RTM codes provide opportunities for practices to expand services and capture reimbursement for remote monitoring of musculoskeletal conditions with lower data transmission and time thresholds than previously required.
2026 RTM Code Family for Musculoskeletal Conditions
Device Supply Codes:
CPT 98977 (existing code):
- 16-30 days of musculoskeletal system monitoring data in 30-day period
- Average national rate: Approximately $40.00
CPT 98985 (NEW for 2026):
- 2-15 days of musculoskeletal system monitoring data in 30-day period
- Average national rate: $40.00
- Allows billing for shorter monitoring periods
Treatment Management Codes:
CPT 98980 (existing code):
- First 20 minutes of treatment management services
- Requires at least one real-time interactive communication
CPT 98981 (existing code):
- Each additional 20 minutes of treatment management
RTM Implementation Considerations
Clinical Applications:
- Post-surgical rehabilitation monitoring
- Home exercise program adherence tracking
- Range of motion progression monitoring
Billing Requirements:
- "Sometimes therapy" designation applies
- Therapy plan of care required when provided by therapists
- Cannot bill multiple device codes in same 30-day period
Revenue Opportunity Analysis
The new codes allow practices to:
- Capture reimbursement for shorter monitoring episodes
- Bill for lower time thresholds (10 vs. 20 minutes)
- Engage patients between in-person visits
- Enhance continuity of care
- Improve functional outcomes through increased monitoring
Best Practice: Start with pilot program for appropriate patient populations (post-surgical, home exercise adherence challenges) before full implementation.
Sources:
- CMS MLN Matters MM14250 - Therapy Code List 2026 Annual Update
- CMS 2026 Medicare Physician Fee Schedule Final Rule
- Nixon Law Group: "CMS Finalizes 2026 Remote Monitoring Reimbursement Updates" (November 18, 2025)
Question 9: How can I prepare my practice for Medicare compliance and audit readiness?
The short answer: Implement systematic internal audit protocols, maintain staff competency through regular training, monitor billing patterns against benchmarks, and ensure documentation consistently meets Medicare requirements.
Proactive Compliance Framework
1. Internal Audit System
Monthly Chart Review Protocol:
- Random selection of 5-10 Medicare patient charts
- Review for documentation completeness
- Verify CPT code selection appropriateness
Documentation Quality Checklist:
- Medical necessity clearly established
- Skilled service justification documented
- Measurable functional goals included
- Progress toward goals documented
2. Staff Training and Competency
Quarterly Training Topics:
- Current Medicare billing requirements
- Documentation best practices
- CPT code selection guidelines
- Modifier usage requirements
Annual Competency Verification:
- Documentation audit review
- Coding accuracy assessment
- Policy knowledge testing
3. Technology Optimization
EMR Compliance Features:
- Templates supporting complete documentation
- Automated prompts for required elements
- KX modifier threshold tracking
When an Audit Occurs
Immediate Steps:
- Notify staff and leadership
- Designate audit response coordinator
- Gather requested documentation promptly
- Consider engaging billing consultant or attorney for complex audits
Documentation Review:
- Ensure records are complete
- Verify medical necessity established
- Confirm skilled service justification
Post-Audit Actions:
- Analyze findings for trends
- Implement corrective actions
- Enhance staff training on deficient areas
Sources:
- CMS Medicare Program Integrity Manual
- APTA Compliance and Risk Management Resources
- Medicare Administrative Contractor guidance documents
Question 10: What other Medicare policy updates should physical therapists know for 2026?
The short answer: Beyond payment and coding changes, physical therapists should be aware of plan of care signature requirement exemptions, equipment pricing updates, and ongoing Medicare Advantage policy developments.
Plan of Care Signature Requirement Exemption
Important 2025 Change Continuing:CMS established an exemption to the burdensome plan of care signature requirement for outpatient therapy services provided with a physician referral.
What Changed:
- Previously: PTs had to send plans of care to referring physicians for signature within 30 days
- If physician didn't return signed POC, PT was responsible for follow-up
- Failure to obtain signature could result in payment denial
Current Policy:
- When physician refers patient for PT services, plan of care signature requirement is waived
- PT still maintains comprehensive treatment plan documentation
- Reduces administrative burden significantly
Exception: This exemption applies only when services are provided pursuant to a physician referral. Other scenarios may still require plan of care certification.
Quality Payment Program Updates
MIPS Performance Threshold:Remains at 75 points for performance years 2026, 2027, and 2028 (corresponding to payment years 2028, 2029, and 2030).
MIPS Value Pathways (MVPs):
- Continued transformation toward specialty-specific quality measures
- Rehabilitative Support for Musculoskeletal Care MVP available
- Simplified reporting through focused measure sets
Looking Ahead: Regulatory Monitoring
Key Areas to Watch:
- Congressional action on telehealth extension
- Medicare payment updates for 2027
- Prior authorization policy developments
Stay Informed:
- Subscribe to CMS Medicare Learning Network updates
- Monitor APTA payment and policy resources
Sources:
- APTA: "APTA Public Policy Priorities, 2025-2026" (February 4, 2025)
- APTA: "CMS Releases Final 2026 Medicare Advantage Rule" (April 30, 2025)
- CMS 2026 MPFS Final Rule
- Alliance for Physical Therapy Quality and Innovation reports
Conclusion: Navigating the 2026 Physical Therapy Compliance Landscape
The 2026 Medicare updates bring the first positive payment increase in five years alongside new opportunities through Remote Therapeutic Monitoring codes and important policy clarifications. While the conversion factor increase is welcome news, practices must understand that RVU adjustments create varied impacts across different service codes.
Key Priorities for 2026:
- Understand Payment Changes: Know how the conversion factor increase and RVU adjustments affect your specific service mix
- Prepare for Telehealth Transition: Physical therapist telehealth privileges expire January 31, 2026—develop contingency plans if this affects your practice
- Explore RTM Opportunities: New codes provide revenue opportunities for practices implementing remote monitoring programs
- Maintain Documentation Excellence: Longstanding Medicare documentation requirements remain critical for compliance and audit preparedness
- Monitor Policy Developments: Stay informed about Congressional action on telehealth, Medicare Advantage policy changes, and future payment updates
Action Steps:
✓ Review your practice's CPT code distribution and analyze payment impact
✓ Assess RTM implementation feasibility for appropriate patient populations
✓ Verify documentation consistently meets Medicare medical necessity standards
✓ Train staff on 2026 changes, especially new RTM codes and telehealth expiration
✓ Implement internal audit protocols to ensure ongoing compliance
Frequently Asked Questions (FAQs)
Q1: When does the 2026 Medicare Physician Fee Schedule take effect?
A: January 1, 2026. All conversion factor changes, new RTM codes, and updated policies became effective on this date.
Q2: Can I still bill Medicare for telehealth physical therapy services?
A: Yes, but only through January 30, 2026. Physical therapist telehealth privileges expire January 31, 2026, unless Congress extends them. After that date, you cannot bill Medicare for PT telehealth services without congressional action.
Q3: Are Patient-Reported Outcome Measures (PROMs) required by Medicare?
A: No. While PROMs are valuable for demonstrating outcomes and considered best practice, they are not currently mandated by CMS for Medicare Part B outpatient physical therapy services. Some alternative payment models may require them, but they are not a standard Medicare requirement.
Q4: What's the KX modifier threshold for 2026?
A: $2,480 for combined physical therapy and speech-language pathology services, and $2,480 for occupational therapy services. The medical review threshold remains at $3,000.
Q5: Do I need direct supervision of my PTA for Medicare patients?
A: No. As of 2025, general supervision (not direct supervision) is permitted for PTAs providing Medicare Part B outpatient services, meaning you don't need to be physically present but must be available for consultation. However, always check your state practice act, as state law may require more stringent supervision.
Q6: How do I bill the new RTM codes?
A: Use CPT 98985 for 2-15 days of musculoskeletal monitoring data, and CPT 98979 for 10-19 minutes of treatment management services. These codes require a therapy plan of care and cannot be billed concurrently with the 16-30 day codes in the same calendar month.
Q7: What documentation is required for medical necessity?
A: Your documentation must establish: (1) objective impairments with functional impact, (2) need for skilled PT intervention, (3) expected functional outcomes, (4) treatment rationale, and (5) correlation between interventions and patient progress. These are longstanding Medicare requirements.
Q8: Will my Medicare reimbursement increase in 2026?
A: It depends on your specific service mix. The conversion factor increased 3.26%, but CMS estimates a net -1% impact for most PT practices due to RVU adjustments that affect individual code payments differently. Analyze your specific CPT code distribution to understand your practice's impact.
Q9: How often does Medicare audit physical therapy practices?
A: CMS does not publish specific audit frequency statistics. Audit selection depends on multiple factors including billing patterns, service volume, geographic location, and targeted review programs. Maintaining compliant documentation practices is essential regardless of audit probability.
References:
Primary CMS Sources:
- Centers for Medicare & Medicaid Services. (2025). Calendar Year 2026 Medicare Physician Fee Schedule Final Rule. Federal Register, October 31, 2025.
- Centers for Medicare & Medicaid Services. (2025). Medicare Physician Fee Schedule Final Rule Summary: CY 2026. MLN Matters Article MM14315.
- Centers for Medicare & Medicaid Services. (2025). Therapy Code List: 2026 Annual Update. MLN Matters Article MM14250.
- Centers for Medicare & Medicaid Services. (2025). KX Modifier Threshold Amounts for Calendar Year 2026. Change Request 13437.
- Centers for Medicare & Medicaid Services. (2025). Telehealth FAQ for Calendar Year 2026. Updated November 14, 2025.
- Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual: Publication 100-04, Chapter 5 - Part B Outpatient Rehabilitation and CORF/OPT Services.
- Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual: Publication 100-02, Chapter 15 - Covered Medical and Other Health Services.
Professional Association Sources:
- American Physical Therapy Association. (2025). "Takeaways From the Proposed 2026 Medicare Physician Fee Schedule, Part 1." APTA News, July 25, 2025.
- American Physical Therapy Association. (2025). "Takeaways From the Proposed 2026 Medicare Physician Fee Schedule, Part 2." APTA News, August 15, 2025.
- American Physical Therapy Association. (2025). "Government Shutdown Ended: Telehealth Flexibilities Extended Until Jan. 30, 2026." APTA News, November 17, 2025.
- American Physical Therapy Association. (2025). "APTA Public Policy Priorities, 2025-2026." February 4, 2025.
- American Physical Therapy Association. (2025). "CMS Releases Final 2026 Medicare Advantage Rule." APTA News, April 30, 2025.
- Alliance for Physical Therapy Quality and Innovation. (2025). "CMS Releases Medicare Physician Fee Schedule Final Rule for CY 2026." November 21, 2025.
Medicare Administrative Contractors:
- Noridian Healthcare Solutions. Per-Beneficiary KX Modifier Thresholds. Medicare Part B Contractor Guidance.
Industry Analysis Sources:
- WebPT. (2025). "What the 2026 Final Rule Means for Rehab Therapists." November 20, 2025.
- AAPC. (2025). "CMS Issues Final Rule for 2026 Medicare Part B Payment Policies." AAPC Knowledge Center, November 7, 2025.
- Nixon Law Group. (2025). "CMS Finalizes 2026 Remote Monitoring Reimbursement Updates." November 18, 2025.
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