"Physical therapy is not a subspecialty of the medical profession and physical therapists are not medical doctors; we are a separate profession that provides a unique service that physicians are unable and untrained to provide."

Letter to the AMA from the APTA, Dec 2009

Thursday, August 11, 2011

Comparative billing report on outpatient physical therapy services with modifier KX

On Tuesday, August 2, 2011, CMS released a national provider comparative billing report (CBR) centered on independent physical therapy providers who practice in the outpatient setting and bill Medicare with modifier KX.

The CBR is similar to the original study distributed last summer except this current study will focus on 2010 billing data and is being sent to 5000 additional or different providers.

If you participated last year, like I did, you WILL NOT GET a new CBR this year.

The CBRs are produced by Safeguard Services under contract with CMS and contain actual data-driven tables and graphs with an explanation of findings that compare a provider’s billing and payment patterns to those of their peers located in the state and across the nation. CMS has received feedback from a number of providers that this kind of data is very helpful to them and encouraged us to produce more CBRs.

You should use these CBRs to provide in-house training to your physical therapists on how to correctly append the -kx modifier for Medically Necessary physical therapy services.

These reports are not available to anyone but the providers who receive them.

To ensure privacy, CMS presents only summary billing information; no patient or case-specific data is included. These reports are an example of a tool that helps providers comply with Medicare billing rules and improve the level of care they furnish to their Medicare patients.

For more information and to review a sample of the outpatient physical therapy services CBR, please visit the CBR Services website or call the SafeGuard Services’ Provider Help Desk, CBR Support Team at 530-896-7080.

Note: Please go to this link on the First Coast Service Options (FCSO) website .


  1. It'd be interesting if state and national peer data happened to be shared with everyone and anyone. I'm curious as to how frequently KX is used.

  2. Selena,

    Physical therapists are terrified that the -KX modifier is a "red flag" for a Medicare audit.

    The sub-contractor processing the PT claims would like this tool to be used as an educational tool but, unfortunately, there are no direct comparisons yet - only individualized reports suitable for self-audits and in-house compliance programs.

    Perhaps if there were a more transparent reporting system physical therapists could have a more open discussion.

    Tim Richardson, PT


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Tim Richardson, PT owns a private practice at Medical Arts Rehabilitation, Inc in Palmetto, Florida. The clinic website is at MedicalArtsRehab.com.

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