Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
commenter stated that occupational therapy services are a
core CORF service. The commenter requested that CMS
clarify that the new G-code would not have a negative
impact on the provision of occupational therapy services to
meet patient needs that are similar to those addressed by
the G-code. The commenter stated that occupational
therapy, as with all therapy services, includes assessment
of the patient level of functioning as an integral part of
the therapy services. Other commenters suggested that
therapists and psychologists assess and treat mental,
cognitive, and emotional functioning as they relate to a
patient’s rehabilitation plan of care. The commenters
further suggested that CMS revisit its decision not to
allow CORF therapists and psychologist to bill the Health
and Behavioral Assessment/Intervention codes (CPT codes
96150 through 96155), which are used to identify and treat
“biopsycholosocial factors important to physical health
problems.” One commenter also requested that the new
G-code include physician work in the RVUs since all other
codes billed by psychologist include physician work.
Another commenter stated that the statute clearly defines
social and psychological services so there is no need for
the development of a G-code.
Response: Section 1861(cc)(2)(B) of the Act defines
the term CORF to mean a facility which provides at least
371