CurrentPremera BluecrossPolicy N/A

Modifier CQ — Physical Therapy Assistant and Modifier CO — Occupational Therapy Assistant

This policy describes how Premera recognizes and reimburses use of the CQ (PT assistant) and CO (OT assistant) modifiers appended to physical medicine and rehabilitation procedure codes and the required plan-of-care modifiers; it applies to Premera and affiliated lines of business and products.

Policy Summary

PayerPremera Bluecross

PolicyModifier CQ — Physical Therapy Assistant and Modifier CO — Occupational Therapy Assistant

Policy CodePolicy N/A

Change TypeReplaced 10% de minimis with mid-point ruleadded CMS counting guidanceclarified 85% reimbursement adjustment

Effective DateN/A

Next Review DateN/A

Key ActionBill supervising therapist on two claim lines: one for the supervising PT/OT with GP or GO and one for the PTA/OTA with CQ or CO and plan-of-care modifier.

SourceLink

POLICY UPDATE CHANGES

Added guidance aligning counting of minutes for timed codes to CMS Publication 100-04 and clarified the mid-point rule for timed codes.

Replaced prior 10% de minimis standard with the mid-point rule for determining when a PTA/OTA furnished a portion of a service requiring a CQ/CO modifier.

Clarified that reimbursement for services appended with CQ and CO will be adjusted to 85% of the provider's applicable contracted fee schedule allowed amount.

85%reimbursement adjustment for services with CQ/CO modifiers

mid-pointtimed-code threshold for applying CQ/CO

GP, GOrequired plan-of-care modifiers

All lines/productsorganizational scope

Records & timedocumentation required

Coverage criteria for therapy assistant services

Claims requirements and coverage adjustments when services are furnished in whole or part by a PTA or OTA:

CQ or CO modifier must be appended when a PTA/OTA furnished all minutes of a service independent of the supervising PT/OT, or when the PTA/OTA furnished a portion of a timed service that exceeds the mid-point of the service (e.g., at least 8 minutes of a 15-minute service).

The appropriate plan-of-care modifier must be appended to all therapy services: GP for outpatient physical therapy and GO for outpatient occupational therapy.

ALL of the following

When the supervising PT/OT rendered any portion of the service: bill two lines on the claim — line one for the supervising PT/OT appended with the appropriate plan-of-care modifier (GP or GO); line two for the PTA/OTA appended with the appropriate therapy assistant modifier (CQ or CO) and the appropriate plan-of-care modifier (GP or GO).

Policy Summary

PayerPremera Bluecross

PolicyModifier CQ — Physical Therapy Assistant and Modifier CO — Occupational Therapy Assistant

Policy CodePolicy N/A

Change TypeReplaced 10% de minimis with mid-point ruleadded CMS counting guidanceclarified 85% reimbursement adjustment

Effective DateN/A

Next Review DateN/A

Key ActionBill supervising therapist on two claim lines: one for the supervising PT/OT with GP or GO and one for the PTA/OTA with CQ or CO and plan-of-care modifier.

SourceLink

On This Page

Trek Health ingests and normalizes Transparency in Coverage data and payer policy updates to give provider organizations a clear view of how commercial reimbursement behaves across markets, payers, and services. Our platform transforms raw payer disclosures into structured intelligence that supports contract evaluation, payer negotiations, and service line strategy. By combining market benchmarks with ongoing policy visibility, Trek helps teams identify variability, risk, and opportunity in commercial reimbursement. The result is faster insight, stronger negotiating positions, and more informed financial decisions.

Claim submission, billing, and modifier use

Billing Rule

Claim submission and billing lines

Bill services rendered by the supervising PT/OT on two separate claim lines: line one for the supervising physical therapist or supervising occupational therapist appended with the appropriate plan-of-care modifier (GP or GO); line two for the PTA or OTA appended with the appropriate therapy assistant modifier (CQ or CO) and the appropriate plan-of-care modifier. If the supervising therapist did not render any of the service, bill a single line for the service rendered by the PTA/OTA with CQ or CO and the appropriate plan-of-care modifier.

Line one: supervising PT/OT services + plan-of-care modifier (GP or GO).
Line two: PTA/OTA services + CQ (PTA) or CO (OTA) + plan-of-care modifier (GP or GO).
Single-line billing allowed only when supervising therapist provided none of the service.

Documentation Required

Modifier use requirements (CQ/CO and plan-of-care modifiers)

Append CQ for outpatient physical therapy services furnished in whole or in part by a physical therapist assistant and CO for outpatient occupational therapy services furnished in whole or in part by an occupational therapy assistant. Always append the appropriate plan-of-care modifier (GP for PT, GO for OT) to the service line.

CQ when PTA furnished all minutes or a portion that exceeds the mid-point of the service (e.g., at least 8 minutes of a 15-minute service).
CO when OTA furnished all minutes or a portion that exceeds the mid-point of the service.
Plan-of-care modifiers: GP = outpatient physical therapy, GO = outpatient occupational therapy.

Definitions

Occupational Therapy Assistant (OTA) — Definition and licensure/certification summary.

DefinitionOccupational Therapy Assistant (OTA): An individual who is licensed, registered, or certified as an OTA by the state in which he or she is practicing, where applicable.

Scope of practiceOTAs may not provide evaluative or assessment services, make clinical judgments or decisions, or develop or manage the plan of care; they act at the direction of and under the supervision of the treating occupational therapist per state law.

Supervision and billingServices furnished by an OTA must be billed by the supervising occupational therapist on the claim; when the OTA furnishes all or a mid-point-exceeding portion of a service, the CO modifier must be appended.

Physical Therapy Assistant (PTA) — Definition and licensure/certification summary.

DefinitionPhysical Therapy Assistant (PTA): An individual who is licensed, registered, or certified as a PTA by the state in which he or she is practicing, where applicable.

Scope of practicePTAs may not provide evaluative or assessment services, make clinical judgments or decisions, or develop or manage the plan of care; they act at the direction of and under the supervision of the treating physical therapist per state law.

Supervision, billing and modifier useServices furnished by a PTA must be billed by the supervising physical therapist on the claim; include CQ when the PTA furnished all minutes or a portion of a timed service that exceeds the mid-point.

OpenPayer

Modifier CQ — Physical Therapy Assistant and Modifier CO — Occupational Therapy Assistant

Coverage criteria for therapy assistant services

Modifiers and timed-code rules

Claim submission, billing, and modifier use

Definitions