2020 Physician Fee Schedule Final Rule

On November 1, 2019, the Centers for Medicare and Medicaid Services released the 2020 Physician Fee Schedule/Quality Payment Program final rule. The rule includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule effective on or after January 1, 2020.

Within the rule, among numerous other policies, CMS finalized a policy regarding application of the new PTA and OTA modifiers on outpatient therapy claims beginning in 2020. As you may know, beginning January 1, 2020, outpatient therapy providers are required to affix a modifier the claim to denote when outpatient therapy is furnished in whole or part by PTA or OTA. Then, beginning on January 1, 2022, payment for outpatient therapy services provided by PTA or OTA will be at 85% of the physician fee schedule. In response to APTA's advocacy efforts, CMS adopted all of APTA's recommended improvements to the policy. Scenarios outlining how to use the new modifiers will be posted to the CMS website in the near future.

CMS also finalized its proposal to adopt increases to the values of the office/outpatient E/M codes in 2021, which requires CMS to make redistributive negative adjustments across specialties to maintain budget neutrality under the Medicare physician fee schedule. Under the plan, physical therapy/occupational therapy could see reductions to CPT code valuations that may result in an estimated 8% decrease in payment in 2021. In total, 36 specialties are facing reimbursement reductions in 2021.

Other policies to be aware of:

  • CY 2020 KX modifier threshold amount: $2,080 for PT and SLP services combined and $2,080 for OT services.
  • Trigger point dry needling codes (20560 and 20561): Although CMS finalized the work and practice expense RVUs for these codes, CMS stated in the final rule that these dry needling codes are non-covered Medicare services in 2020.
  • CMS adopted new regulations that permit CMS to revoke or deny a physician or other eligible professional's Medicare enrollment when such professional's actions result in patient harm.
  • CMS finalized changes to the PT/OT specialty measure set for MIPS in 2020.
  • CMS will continue to reweight the Promoting Interoperability category for physical therapists in 2020.

APTA is in the process of determining next steps to respond to the anticipated Medicare cuts in 2021 and are exploring all potential policy solutions and strategies. We will leverage every possible opportunity to change this flawed policy. We also are reaching out to our partners as well as the other impacted professions to set up calls and discuss strategy and how we might work together moving forward.

Questions regarding the 2020 Medicare Physician Fee Schedule final rule should be directed to


Kara R. Gainer, JD

Director of Regulatory Affairs

American Physical Therapy Association

1111 North Fairfax Street

Alexandria, VA 22314


2020 PFS Final Rule Detailed Summary.pdf (380.8 KB)



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