On March 17, 2020, the Department of Defense published final regulations stating that TRICARE will start paying for PTA and COTA services for dates of service on and after April 17, 2020.
TRICARE will be following Medicare supervision rules. So, a physical therapist needs to be in the office suite when a PTA is treating and an occupational therapist needs to be in the office suite when a COTA is treating. However, the supervising therapist does not need to be same room as the assistant, only in the same office suite.
The regulations specifically state that TRICARE will not pay for aide or tech services (like Medicare).
TRICARE will be following Medicare billing rules. So, PTA claims should be filed under the supervising physical therapist and COTA claims should be filed under the supervising occupational therapist. Claims for PTA or COTA services cannot be filed under a physician’s provider number.
The TRICARE regulations do not currently specify whether the CQ or CO modifier needs to be added to claims. We expect that sometime between now and the April 17 effective date, TRICARE will address this issue. TRICARE is likely to require the CQ and CO modifiers and eventually apply the 15% discount to PTA and COTA services that Medicare will apply starting in 2022.