UnitedHealthcare requires 'GP' Always Therapy Modifier effective April 1, 2020

UnitedHealthcare will require the use of a 'GP' modifier for all billed physical medicine services effective 04/01/2020. 

You may recall that UHC had planned to implement this policy for their Community Based health plans only; however, we have confirmed that United will be requiring the use of the GP modifier for all lines of business (including Optum plans).  

Please note that certain clearing houses have begun to implement an educational phase of this policy and are flagging your claims (e.g., Office Ally).  The NYSCA has reached out to Office Ally in response to their flagging of UnitedHealthcare claims.  According to Office Ally, the claims in your 'claims fix' file will 'picked up' (reprocessed) within 5 business days. DO NOT DELETE THESE CLAIMS FROM YOUR CLAIM FIX OR THE CLAIMS WILL NOT BE PICKED.  We have tested this process and can report that the flagged UnitedHealthcare 'GP' claims were picked up by Office Ally without our intervention.  

The 'GP' modifier will be required for all United Healthcare claims submitted after 3/31/20.

Rejection note from Office Ally:

REJECTED  P4999umAT SmartEdit (umAT) [Pattern 26693] Beginning 4 01 20, therapy charges must be billed with the required modifier GP, GN, or GO. Claims submitted on or after that date must have a required modifier. Please repair now in advance of this deadline.

What do I need to do?

To ensure you are compliant with this billing requirement, incorporate the 'GP' modifier for all physical medicine services rendered to all UnitedHealthcare enrollees.  As always, it is your responsibility to ensure you are billing the most appropriate service(s) as defined by each CPT code.   You can also review the UnitedHealthcare notice at UHCProvider.com located at:

https://www.uhcprovider.com/content/dam/provider/docs/public/commplan/payment-policy/MultiState-Updated-Procedure-to-Modifier-Policy-Professional.pdf

According to the Centers of Medicare and Medicaid Services (CMS), MM10176:

The following “Always Therapy” HCPCS codes require a GN (speech therapy), GO (occupational therapy), or GP physical therapy) modifier, as appropriate. Descriptors for these codes are included as an attachment to CR 10176.  
92507 92508 92526 92608 92609 96125 97012 97016 97018 97022 97024 97026 97028 97032 97033 97034 97035 97036 97039 97110 97112 97113 97116 97124 97139 97140 97150 97530 97533 97535 97537 97542 97750 97755 97760 97761 97762 97799 G0281 G0283 G0329 

Please note that some of these services are not applicable to the practice of chiropractic in our state; however, the 97*** series of codes (including ultrasound, electrical muscle stimulation, therapeutic exercise, etc) are commonly utilized in the care of our patients.  You can read additional information relative to this at:

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM10176.pdf

If I render and bill for 1-2 regions of CMT and therapeutic exercise, which codes receive the GP modifier?

UHC-GP 

Haven't we already implemented the GP modifier?

Most of you are already utilizing the GP modifier, as these have been required by the Veterans Administration.  Medicare also requires the GP modifier for physical medicine codes; however, since Medicare does not cover physical medicine services when rendered by Doctors of Chiropractic, your billed physical medicine services would include both the GP and GY (non-covered service) modifiers.  

If you have any questions regarding the above, please feel free to contact the NYSCA Insurance Committee, your local NYSCA district, UnitedHealthcare and/or your claims clearinghouse to avoid any delays in the processing of your claims.

How this impacts Medicare claims

Please recall that CMS implemented the 'Always Therapy' policy on 1/1/2018.  National Government Services (NGS) has just released the following reminder on this same topic:

CHIROPRACTORS BILLING MEDICARE FOR THERAPY SERVICES

Chiropractors in the Medicare fee-for-service realm are only allowed to be considered for spinal manipulation via submission of CPT codes 98940‒98942. Medicare pays for these services when they are reasonable and medically necessary and meet all coverage guidelines. 

Chiropractors do also perform additional services that Medicare does not consider for coverage. Any service outside of spinal manipulation is denied by Medicare as noncovered. Therapy services provided by a chiropractor, although noncovered must be submitted according to therapy guidelines along with one of the therapy modifiers. CMS Internet-Only-Manual, Publication 100-4, Medicare Claims Processing Manual, Chapter 5, Section 10.4 (B) indicates, “claims containing any of the ‘always therapy’ codes must have one of the therapy modifiers appended (GN, GO, GP). Contractors shall return claims for ‘always therapy’ codes when they do not contain appropriate therapy modifiers for the applicable HCPCS codes.” Therefore, if a chiropractor submits an “always therapy” code they must submit the appropriate physical therapy modifier with the code in order for the service to deny as noncovered. If the modifier is not appended the service will reject for not containing a valid modifier.

To determine which codes are considered “always therapy” services you will need to review the Annual Therapy Update provided by CMS that establishes this list of codes that are applicable.

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