If you’re a physical therapist, you know the frustration all too well: You’ve completed a thorough evaluation, developed a comprehensive treatment plan, and started delivering care—but you’re still chasing down a physician’s signature on your Plan of Care (POC). Days turn into weeks. Follow-up faxes pile up. Phone calls go unreturned. And all the while, you’re wondering whether Medicare will actually pay for the services you’ve already provided.

For years, the POC signature requirement has been one of the most aggravating administrative burdens in outpatient therapy. But effective January 1, 2025, CMS made a groundbreaking change that eliminates much of this headache: physical therapists no longer need a physician signature on initial POC certifications—only proof that the POC was submitted to the referring provider within 30 days.

This is a major win for therapy practices, and in this comprehensive guide, we’ll break down exactly what changed, what it means for your practice, what still requires signatures, and how to implement this new rule effectively.

The Big Change: CMS’s New POC Certification Exception

Within the 2025 Medicare Physician Fee Schedule Final Rule (CMS-1807-F), published on November 1, 2024, CMS finalized amendments to the certification regulations that fundamentally change how physical therapists handle initial POC certification.

What’s Different Now?

The Old Rule (Before January 1, 2025):

  • PT creates a plan of care after the initial evaluation
  • PT submits POC to the referring physician/NPP (non-physician practitioner)
  • PT must obtain the physician’s signed and dated signature on the POC
  • Without that returned signature, Medicare could deny payment—even if services met medical necessity

The New Rule (Effective January 1, 2025):

  • PT creates a plan of care after the initial evaluation
  • PT must have a signed and dated referral or order from the physician/NPP on file
  • PT must submit the POC to the referring provider within 30 days of the initial evaluation
  • PT must document evidence that the POC was transmitted
  • No return signature required for initial certification
  • Under the new exception, silence serves as consent—if the referring provider doesn’t return the signature or indicate changes, the POC is deemed certified

This change is codified at 42 CFR § 424.24(c) and detailed in the Federal Register at 89 Fed. Reg. 97710, 97912-97918. CMS also updated the Medicare Benefit Policy Manual, Chapter 15, Section 220 to reflect these changes.

According to the official CMS fact sheet, this policy change “lessens the administrative burden for therapists and physician/NPPs while maintaining appropriate oversight of therapy services.”

Why This Change Matters: The Real-World Impact

This isn’t just regulatory minutiae—it’s a fundamental shift that addresses one of the most frustrating operational challenges in outpatient therapy.

The Administrative Burden Relief

Before this change, obtaining POC signatures often involved:

  • Multiple fax attempts to busy physician offices
  • Follow-up phone calls to front desk staff who aren’t familiar with therapy requirements
  • Tracking systems to monitor outstanding signatures across dozens of patients
  • Staff time dedicated solely to signature collection
  • Payment delays while waiting for signatures to come back
  • Denial risk if signatures never arrived, even when care was medically necessary

According to the American Physical Therapy Association (APTA), the 2025 change came after years of advocacy, with APTA members sending more than 2,600 letters to CMS during the comment period. The APTA noted that this change “reduces administrative burden, provides more flexibility to the physical therapy workforce, and improves access to care.”

Faster Treatment, Faster Payment

With the new exception:

  • No more chasing signatures for weeks after treatment has started
  • Faster revenue cycle since you can bill for services without waiting for signature return
  • Reduced denial risk related to missing or late POC signatures
  • Less administrative overhead tracking outstanding POCs
  • Better patient access since administrative delays no longer impede care

Real Practice Impact: A Case Study

Before 2025: A solo practitioner sees 15 new Medicare patients per month. Each POC requires an average of 3 faxes and 2 phone calls to obtain a signature, taking approximately 30 minutes of staff time per patient. That’s 7.5 hours per month (90 hours per year) spent solely on signature collection—time that could be spent on patient care, marketing, or other revenue-generating activities.

After January 1, 2025: The same practitioner now needs only to fax the POC once and document transmission—about 5 minutes per patient. That’s 1.25 hours per month (15 hours per year) spent on POC submission, saving 75 hours annually. At a typical staff rate of $20/hour, that’s $1,500 in direct cost savings, not counting reduced denial write-offs.

What Still Requires a Physician Signature

While the 2025 change is significant, it’s critical to understand what hasn’t changed. CMS was explicit about the limitations of this exception.

1. POC Recertifications (Every 90 Days)

Physician signatures are still required for POC recertifications. According to the final rule, “CMS is not establishing an exception to the signature requirement for purposes of recertification of the therapy plan of treatment, as physicians and NPPs should still be required to sign a patient’s medical record to recertify their therapy treatment plans to ensure that a patient does not receive unlimited therapy services without a treatment plan signed and dated by the patient’s physician/NPP.”

What this means:

  • Initial POC certification: No signature required (just proof of submission)
  • Recertification at 90 days: Signature required
  • Recertification when treatment plan significantly changes: Signature required

This is a crucial compliance point. As detailed in our comprehensive guide to audit-proof documentation, many practices get tripped up by missing recertification signatures, which can trigger denials or audits.

2. Direct Access Patients

If you’re treating a Medicare beneficiary under direct access (meaning they came to you without a physician referral), you still need a physician signature on the POC.

Here’s why: The new exception only applies when there’s already a signed and dated referral or order from a physician/NPP on file. Direct access patients, by definition, don’t have that initial referral, so the traditional POC signature requirement remains in effect.

Direct access workflow:

  1. Patient self-refers to physical therapy (allowed under Medicare rules in most states)
  2. PT performs initial evaluation and develops POC
  3. PT identifies an appropriate physician to certify the POC (often the patient’s primary care physician)
  4. PT submits POC to physician
  5. Physician must sign and return the POC for Medicare payment

For more on this topic, see APTA’s guidance on direct access and Medicare.

3. Home Health Plans of Care

The 2025 exception applies specifically to outpatient therapy services under Medicare Part B. Home health plans of care (Form CMS-485) continue to follow separate certification requirements under the home health benefit and are not affected by this change.

POC Requirements: What Must Be Included

Whether you’re submitting an initial POC or a recertification, the content requirements haven’t changed. Your POC must include specific elements to meet Medicare standards.

Required Elements of a Compliant POC

According to CMS regulations and Medicare Administrative Contractor (MAC) guidance, your POC must document:

  1. Diagnosis and relevant medical history

    • ICD-10 codes for conditions being treated
    • Relevant comorbidities affecting treatment
    • Pertinent surgical history or precautions

  2. Long-term treatment goals (functional outcomes)

    • Measurable, functional goals (not impairment-based)
    • Realistic timeframe for achievement
    • Patient-centered language

  3. Short-term goals (measurable objectives)

    • Specific, objective measures (ROM, strength, gait speed, etc.)
    • Progression toward long-term goals

  4. Treatment frequency and duration

    • Number of visits per week
    • Estimated duration of treatment episode
    • Justification for frequency

  5. Type(s) of therapy services to be provided

    • Specific interventions planned (therapeutic exercise, manual therapy, gait training, etc.)
    • Rationale for skilled therapy necessity

  6. Certification statement and signature line

    • Statement that plan meets Medicare coverage criteria
    • Space for physician/NPP signature and date
    • NPI of certifying provider

POC Content Example

Here’s what a compliant initial POC might look like:

Patient: Jane Smith, DOB: 03/15/1950

Diagnosis: M25.561 - Pain in right knee; M17.11 - Unilateral primary osteoarthritis, right knee

Medical History: 68-year-old female referred by Dr. Johnson (NPI: 1234567890) for right knee pain limiting mobility. Gradual onset over 6 months. X-rays show moderate osteoarthritis. Patient declined surgical consultation at this time. Medically cleared for PT per referral dated 10/15/2025.

Long-Term Goals (8 weeks):

  1. Patient will ambulate 1 mile continuously without assistive device and pain <3/10 to enable return to daily walks with spouse.
  2. Patient will ascend/descend full flight of stairs without rail and pain <3/10 to enable independent access to bedroom on second floor.

Short-Term Goals (4 weeks):

  1. Increase right knee flexion ROM from 95° to 115° to improve gait and stair climbing.
  2. Increase right quadriceps strength from 4-/5 to 4+/5 to improve functional mobility.
  3. Decrease pain rating from 6/10 to 3/10 with ADLs.

Treatment Plan: Frequency: 2x/week for 8 weeks (16 visits estimated) Interventions: Therapeutic exercise for lower extremity strengthening and ROM; manual therapy for joint mobilization and soft tissue mobility; gait training; functional training for stairs; neuromuscular reeducation for movement patterns; patient education for home exercise program and activity modification.

Rehabilitation Potential: Good, based on patient motivation, medical stability, and response to initial evaluation.

Certification: I certify that the services on this plan of care are or were required because this patient needed skilled physical therapy services and that these services are or were provided while the patient was under my care.

Physician Signature: ___________________ Date: ___________

For assistance with proper diagnosis coding, see our guide to ICD-10 codes for physical therapy in 2025.

The 30-Day Submission Deadline: Critical Compliance Point

Under the new rule, you must document evidence that the POC was transmitted to the referring physician/NPP within 30 days of the initial evaluation. This 30-day deadline is non-negotiable.

What “Transmitted” Means

CMS didn’t prescribe a specific transmission method, so acceptable methods include:

  • Fax (with transmission confirmation report)
  • Secure email (with delivery confirmation)
  • Electronic health record (EHR) portal submission
  • Direct mail (with certified receipt)

Critical: You must maintain documentation of transmission—a fax confirmation report, email delivery receipt, portal submission timestamp, or postal tracking number.

How to Track the 30-Day Deadline

Missing the 30-day deadline can result in claim denials. Here’s a workflow to ensure compliance:

Day 1: Complete initial evaluation

  • Create POC immediately after evaluation
  • Note the 30-day deadline (calendar day, not business day)
  • Set reminder for Day 7, Day 21, and Day 28

Within 7 days: Submit POC to referring provider

  • Transmit via fax, secure email, or EHR portal
  • Save transmission confirmation
  • Document in patient chart: “POC transmitted to Dr. [Name] via fax on [date]. Confirmation report filed.”

Day 21 check: Verify submission occurred

  • If not yet submitted, prioritize immediately
  • Review any barriers to timely submission

Day 28 alert: Final warning before deadline

  • If submission hasn’t occurred, this is your last chance

Automated Deadline Tracking

Manual deadline tracking across dozens of active patients is error-prone. Modern EMR systems should automate this process. Proactive Chart includes:

  • Automatic 30-day deadline calculation from evaluation date
  • Dashboard alerts showing POCs approaching deadline
  • Automated reminders at configurable intervals (7, 14, 21, 28 days)
  • One-click eFax integration to submit POCs directly from the platform
  • Automatic filing of fax confirmation reports in patient chart

This automation ensures you never miss the 30-day deadline, protecting your revenue and keeping you compliant. Learn more about our integrated eFax solution.

Implementing the New POC Rule in Your Practice

The regulatory change is straightforward, but implementing it effectively requires updating your workflows, training staff, and adjusting documentation practices.

Step 1: Update Your POC Template

Revise your POC template to include:

  • Clear field for documenting the date of initial evaluation
  • Checkbox or field to confirm signed referral/order on file
  • Field for transmission date
  • Field for transmission method (fax, email, portal, mail)
  • Space to attach or reference transmission confirmation

Step 2: Train Your Team

All treating therapists, PTAs, and administrative staff should understand:

  • What changed: No signature required for initial certification (only proof of submission)
  • What didn’t change: Signatures still required for recertifications and direct access
  • The 30-day deadline: Non-negotiable submission requirement
  • Documentation requirements: Must prove transmission occurred
  • Billing implications: Can bill for services once POC is transmitted (don’t need to wait for signature)

Step 3: Revise Your Billing Workflow

Old workflow:

  1. Provide treatment
  2. Submit POC to physician
  3. Wait for signed POC to return
  4. Bill for services once signature received

New workflow (effective January 1, 2025):

  1. Provide treatment
  2. Submit POC to physician within 30 days
  3. Document transmission evidence
  4. Bill for services (no need to wait for signature)

This change significantly accelerates your revenue cycle. For best practices on billing workflows, see our complete PT billing and RCM guide.

Step 4: Create an eFax Workflow

Since you need to transmit POCs and maintain proof of transmission, integrated eFax is the most efficient method. A streamlined eFax workflow looks like this:

  1. Complete initial evaluation and generate POC in your EMR
  2. Click “Send POC” button in your EMR
  3. Select referring provider from your provider database (fax number auto-populates)
  4. Send eFax directly from EMR—no scanning, no separate fax machine
  5. Confirmation report automatically filed in patient chart
  6. Dashboard updated showing POC submitted and deadline met

Proactive Chart’s integrated eFax functionality enables exactly this workflow. You never leave the platform, and the entire process takes less than 60 seconds per patient. Read more about the benefits in our article on why integrated eFax improves practice efficiency.

Step 5: Monitor Compliance

Set up internal monitoring systems to ensure ongoing compliance:

  • Weekly review: Dashboard report showing all POCs approaching 30-day deadline
  • Monthly audit: Random sample of 5-10 charts to verify proper documentation of transmission
  • Quarterly training refresher: Reinforce the new rule with staff

Common Questions About the 2025 POC Rule Change

Q: Can I bill for treatment provided before submitting the POC?

A: Yes, as long as you submit the POC within 30 days of the initial evaluation and maintain the signed referral/order on file. CMS clarified that “payment should be made available for any therapy services furnished prior to a physician/NPP-modified treatment plan if all payment requirements are met.”

However, best practice is to submit the POC within 7 days of the initial evaluation to allow time for the physician to provide feedback before you’ve delivered significant treatment.

Q: What if the physician returns the POC with modifications?

A: If the referring physician returns the POC with changes, you should:

  1. Review the modifications
  2. Incorporate appropriate changes into the treatment plan
  3. Document the physician’s feedback in the patient chart
  4. Continue treatment according to the modified plan

CMS noted that they “did not adopt a timeline restriction for physicians/NPPs to make changes to the therapist-established treatment plan.” So the physician can provide feedback at any point, even after the 30-day window.

Q: Do I need the physician’s signature on the referral, or just an order?

A: You need a signed and dated referral or order from the physician/NPP. This can be:

  • A written prescription for physical therapy
  • A referral form with physician signature
  • An order in the patient’s medical record
  • An electronic order through an EHR system

As long as it’s signed and dated by the physician/NPP and indicates the need for physical therapy, it meets the requirement.

Q: What if I’m treating a patient with multiple physicians—which one needs to certify the POC?

A: The referring physician/NPP (the one who ordered physical therapy) is the one who should receive the POC and provide certification. This is typically documented on the initial referral or order.

If the patient has multiple physicians managing different conditions, the POC should go to the physician who referred for therapy, even if another physician is managing the specific diagnosis being treated in PT.

Q: Does this change apply to Medicare Advantage plans?

A: Medicare Advantage (Part C) plans are administered by private insurers and may have different POC requirements than traditional Medicare (Part B). While many Medicare Advantage plans adopt traditional Medicare rules, always verify POC requirements with the specific plan before assuming the 2025 exception applies.

Q: Can I use electronic signature for POC recertifications?

A: Yes, electronic signatures are acceptable for POC certifications and recertifications, as long as they meet the requirements of the Electronic Signatures in Global and National Commerce Act (E-SIGN Act) and comply with your state’s regulations. The signature must be attributable to a specific individual and include the date.

Q: What if the physician’s office refuses to sign recertifications?

A: Unfortunately, obtaining recertification signatures remains a requirement under the 2025 rule (the exception only applies to initial certification). If a physician’s office is consistently unresponsive, consider:

  • Educating the office staff on Medicare requirements
  • Providing a simple one-page recertification form (not a full POC)
  • Using eFax for faster transmission and confirmation
  • Discussing the issue directly with the physician
  • If necessary, discussing alternative referring providers with the patient

Q: Does the 30-day deadline count business days or calendar days?

A: Calendar days. CMS specified 30 days from the date of the initial evaluation, without excluding weekends or holidays. So if your initial evaluation is on January 5, your POC must be transmitted by February 4.

Q: What happens if I miss the 30-day deadline?

A: Missing the 30-day deadline could result in claim denials for services provided during that episode of care. If you realize you’ve missed the deadline:

  1. Submit the POC immediately
  2. Document the late submission and reason for delay
  3. File the claim as usual, with supporting documentation
  4. Be prepared to appeal if the claim is denied

The best approach is to implement systems (like Proactive Chart’s automated deadline tracking) to prevent missed deadlines in the first place.

Q: Can I still request a physician signature even though it’s not required?

A: Yes. The 2025 change creates an exception to the signature requirement—it doesn’t prohibit obtaining signatures. If your practice prefers to continue obtaining signatures on initial POCs (for additional documentation or physician communication), you can continue to do so. The benefit is that you’re no longer required to obtain the signature before billing.

The Intersection with Other 2025 Medicare Changes

The POC certification change is one of several important Medicare updates affecting physical therapy practices in 2025. Understanding how these policies interact is important for comprehensive compliance.

MIPS Reporting Requirements

If you’re a Medicare provider seeing a significant volume of Part B patients, you’re likely subject to MIPS (Merit-based Incentive Payment System) reporting. Your POC documentation supports several MIPS quality measures, including:

  • Functional outcome assessment (using validated tools like the AM-PAC or FOTO)
  • Risk assessment and plan of care documented
  • Patient-centered care planning

Learn more in our comprehensive guide to MIPS for physical therapy in 2025.

The 8-Minute Rule

Your POC should align with your actual treatment approach documented in daily notes. If your POC states you’ll provide therapeutic exercise and manual therapy, those services should appear consistently in your billing using appropriate time-based codes. Discrepancies between your POC and actual treatment can raise audit red flags.

Review our detailed breakdown of the Medicare 8-minute rule for 2025 to ensure proper billing.

Telehealth POC Requirements

If you’re providing telehealth services to Medicare patients, the POC certification rules apply the same way as for in-person services. The initial evaluation can be conducted via telehealth, and the POC must still be submitted within 30 days of that evaluation. Be aware that Medicare telehealth rules for PT in 2025 include specific requirements about which services can be provided remotely.

PTA Supervision and POCs

The POC is established by the physical therapist, not the PTA. Even if a PTA provides some or all of the treatment, the supervising PT is responsible for creating the POC, submitting it to the physician, and ensuring compliance with certification requirements. Review current PTA supervision requirements for 2025 to ensure your practice is compliant.

How Proactive Chart Streamlines POC Management

The 2025 POC rule change reduces administrative burden—but only if you have systems in place to track deadlines, document transmission, and ensure compliance across all your patients. That’s where modern EMR technology becomes essential.

Automated POC Tracking

Proactive Chart’s POC management system includes:

✅ Automatic deadline calculation: System calculates the 30-day deadline from the initial evaluation date ✅ Dashboard visibility: See all POCs requiring submission at a glance ✅ Color-coded alerts: Green (submitted), yellow (approaching deadline), red (overdue) ✅ Automated reminders: Configurable notifications at 7, 14, 21, and 28 days ✅ One-click generation: Create compliant POCs from evaluation documentation ✅ Integrated eFax: Send POCs directly to referring providers without leaving the platform ✅ Automatic documentation: Fax confirmation reports filed in patient chart automatically ✅ Recertification tracking: Separate alerts for 90-day recertification deadlines ✅ Audit reports: One-click compliance reports showing all POC submission dates

The Proactive Chart POC Workflow

Here’s what the complete workflow looks like in Proactive Chart:

  1. Complete initial evaluation using customizable evaluation templates
  2. Click “Generate POC” button—system auto-populates POC with evaluation findings, goals, and treatment plan
  3. Review and finalize POC—make any needed edits
  4. Click “Send POC”—referring provider’s fax number auto-populates from referral
  5. Confirm send—eFax transmits POC, confirmation report filed automatically
  6. Dashboard updates—POC marked as submitted, 30-day deadline met
  7. System sets recertification reminder for 90 days from evaluation date

Total time: Less than 2 minutes per patient. No scanning, no separate fax machine, no manual tracking spreadsheets.

Compliance Confidence

Beyond efficiency, Proactive Chart gives you audit-ready documentation:

  • Timestamped transmission records for every POC
  • Filed confirmation reports proving delivery
  • Audit reports showing submission dates for all patients
  • Automatic alerts preventing missed deadlines
  • Complete documentation trail for compliance defense

If you’re ever audited, you can generate a comprehensive POC compliance report in seconds, demonstrating that every POC was submitted timely with documented proof of transmission.

To learn more about how medical billing software helps small practices maintain compliance while reducing administrative burden, see our guide to medical billing software for small practices.

Looking Forward: What This Means for the Future of PT Practice

The 2025 POC certification change represents a significant shift in CMS policy—and it didn’t happen by accident. It’s the result of years of advocacy by APTA and thousands of practicing therapists who documented the real-world impact of unnecessary administrative burdens.

The Advocacy Win

According to APTA’s announcement, this change mirrors provisions in the REDUCE Act (H.R. 7403), legislation backed by APTA that would permanently codify reduced administrative requirements for therapy services. The fact that CMS adopted this change through rulemaking demonstrates the agency’s recognition that excessive administrative burdens:

  • Don’t improve patient outcomes
  • Don’t reduce fraud or abuse
  • Create barriers to timely care
  • Waste clinician time that could be spent on patient care

What Could Come Next?

While the 2025 change is limited to initial POC certification, there’s hope for future expansions:

  • Recertification signature elimination: If the initial certification exception proves successful, CMS may consider similar relief for recertifications
  • Direct access signature relief: Future rules might address the POC signature requirement for direct access patients
  • Therapy cap documentation: Continued simplification of threshold reporting and functional limitation reporting
  • Evaluation complexity: Potential changes to evaluation code requirements and documentation

The 2025 POC change demonstrates that advocacy works—and that CMS is willing to eliminate administrative requirements that don’t serve a clinical purpose.

The Role of Technology

As CMS continues to modernize regulations, practices that leverage technology will have a significant advantage. EMR systems like Proactive Chart that automate compliance allow you to:

  • Adapt quickly to regulatory changes
  • Reduce staff training burden when rules change
  • Maintain compliance with less manual effort
  • Focus resources on patient care instead of administrative tasks

The practices that thrive in the coming years will be those that embrace technology to handle the administrative complexity of modern healthcare.

Conclusion: A Welcome Relief, With Compliance Reminders

The elimination of the physician signature requirement for initial POC certification is one of the most significant administrative relief provisions for physical therapy in recent years. Starting January 1, 2025, you can bill for services as soon as you’ve submitted the POC to the referring provider—no more waiting weeks for a signature to arrive.

But while this change reduces burden, it doesn’t eliminate compliance responsibilities. You must:

  • ✅ Maintain a signed referral or order on file
  • ✅ Submit the POC within 30 days of the initial evaluation
  • ✅ Document proof of transmission (fax confirmation, email receipt, etc.)
  • ✅ Continue to obtain signatures for recertifications
  • ✅ Follow traditional signature requirements for direct access patients

Implementing effective systems—whether manual tracking spreadsheets or automated EMR features like those in Proactive Chart—is essential to ensure you never miss a deadline and always have audit-ready documentation.

The bottom line: This change means less time chasing signatures, faster payment, and more time for what matters most—delivering excellent patient care. Make sure your practice is ready to take full advantage of the new rule on January 1, 2025.

Ready to streamline your POC management? Proactive Chart’s automated POC tracking, integrated eFax, and compliance dashboards make it easy to stay compliant with the new Medicare rules. Learn more about Proactive Chart or schedule a demo to see how we can simplify your practice operations.

References and Additional Reading:

Disclaimer: This article provides general guidance on Medicare POC certification requirements effective January 1, 2025. Always consult with a compliance specialist, billing expert, or legal advisor for your specific situation. Medicare rules may vary by Medicare Administrative Contractor (MAC) region, and individual payer policies may differ. This information is current as of November 2025 but may be subject to future updates or clarifications from CMS.