Medicare Guide Start here Fighting denials Your conditions The Evenity denial Physical therapy The car crash The options Contacts Sources
Section 3

Physical therapy — the clearest case of all

Of everything researched, this is the sharpest difference between the two systems — and it touches all three conditions: the trigeminal neuralgia, the post-crash recovery, and the osteoporosis.

The headline

Original Medicare has no prior authorization for outpatient physical therapy. None — not in any state, at any dollar amount, ever. And no visit limit.

The hard therapy caps were repealed in 2018. What remains are soft thresholds that trigger paperwork, not denials. Utilization is controlled entirely after the fact, through claim review — never by making you ask permission first.

Original MedicareYour UHC Group MA PPO
Prior authorizationNever. None.First 6 visits free, then full clinical review
Visit limitNone — no cap, no annual maximumEffectively capped by each authorization block
What happens as costs add upPast $2,480 the therapist adds a modifier attesting medical necessity; claims keep paying. Past $3,000 a claim may be selected for review afterward.Re-authorization required, each time, indefinitely
Who decides necessityThe treating therapist and physician; review only after the factA plan reviewer applying proprietary criteria, before care
Choice of clinicAny Medicare-certified provider, nationwideNetwork-based
Cost with a supplement$283 deductible, then essentially $0 regardless of visit countPlan copay per visit
2026 thresholds from CMS and the American Physical Therapy Association. Note the $2,480 and $3,000 figures are not caps — claims above them continue to be paid.

The scale difference is worth seeing plainly: traditional Medicare completed roughly 625,000 prior authorization reviews in all of fiscal 2024, across every program combined. Medicare Advantage plans made 52.8 million determinations in the same period.

The APTA's November 2025 report on administrative burden found that 83% of physical therapists say prior authorization has caused patients to abandon treatment altogether, and 30% report waiting one to two weeks for each authorization. That is the mechanism by which a benefit that technically exists becomes one you can't actually use.

The single most useful thing to know — the Jimmo standard

If therapy is ever denied or cut off because someone has "plateaued," is "not improving," or is "chronic and stable," that denial is contrary to a binding federal court settlement and should be appealed on exactly that basis.

Jimmo v. Sebelius (2013) required CMS to issue a corrective statement holding that coverage "does not turn on the presence or absence of a beneficiary's potential for improvement… but rather on the beneficiary's need for skilled care," and that "a beneficiary's lack of restoration potential cannot, in itself, serve as the basis for denying coverage." Maintenance therapy — to preserve function or slow deterioration — is covered.

And it binds Medicare Advantage plans too

This is the part that makes it enforceable here. Under 42 CFR 422.101(b)(6), Medicare Advantage plans may apply their own internal coverage criteria only where Medicare's coverage criteria are not fully established. Because Jimmo and the Medicare Benefit Policy Manual fully establish the maintenance-therapy standard, a plan may not substitute proprietary "improvement" criteria for it.

So an improvement-based denial isn't just wrong on the merits — it's arguably a regulatory violation. Say so, and cite the regulation by number.

The framing that wins in the therapist's notes:
Not "the patient is improving," but — "the specialized judgment, knowledge, and skills of a qualified therapist are necessary for the performance of a safe and effective maintenance program, because of [specific medical complexity]." That is close to verbatim from the CMS corrective statement, and it's what the manual requires. Ask the therapist to write it explicitly and to cite Medicare Benefit Policy Manual Chapter 15, §220.

The Center for Medicare Advocacy publishes, free, a Jimmo appeal letter template and a self-help packet for outpatient therapy denials. These are the best materials on this subject anywhere, and they're written to be used by patients rather than lawyers.

If therapy is being approved a few visits at a time

42 CFR 422.138 requires that approval of a prior authorization request for a course of treatment "must be valid for as long as medically reasonable and necessary to avoid disruptions in care." CMS adopted this specifically to stop plans from re-authorizing every two or three visits, which had been common practice.

If that's happening, it is arguably a regulatory violation rather than just an annoyance. Raise it in the appeal and in a complaint to Medicare at 1-800-633-4227.

Post-acute rehab after the crash

This is where the gap between the two systems is largest and most measurable. Under Original Medicare, admission to an inpatient rehabilitation facility is a clinical decision between the hospital and the rehab physician — no insurer approval step exists. Under Medicare Advantage in 2024, according to the HHS Inspector General:

SettingDenial rate, all plansUnitedHealth GroupOverturned on appeal
Long-term care hospital65%71%36%
Inpatient rehabilitation facility54%66%43%
Skilled nursing facility12%14%95%
Only 31% of inpatient rehab denials and 18% of skilled nursing denials are ever appealed. A separate 2022 OIG audit found 13% of MA prior authorization denials would have been covered outright under Original Medicare, naming inpatient rehabilitation as a top category.
One detail specific to a car crash

Inpatient rehab facilities must maintain a required share of patients with certain qualifying conditions in order to keep their designation — and "major multiple trauma" is on that list. A polytrauma patient after a crash is squarely someone rehab facilities want to admit. That makes a plan denial of inpatient rehab in this situation particularly contestable, and worth saying to the facility's admissions team as well as to the plan.

If rehab or skilled nursing is being cut off — the fast-track appeal

When a skilled nursing facility, home health agency, or rehab facility says services are ending, you get a Notice of Medicare Non-Coverage at least two days beforehand. That notice starts a clock.

Do not appeal this to UnitedHealthcare. Appeal it to the independent reviewer by noon the day before services are set to end. In Medicare Advantage this runs through the plan's independent review entity rather than the state quality organization, but the key protections are the same: the burden of proof is on the plan, not on you, and coverage continues while the appeal is pending.

For a hospital discharge, the equivalent is the Important Message from Medicare, and the Texas quality review organization is Acentra Health, 1-888-315-0636. Call them before leaving.

Home health

Under Original Medicare, home health has no prior authorization, no cost-sharing at all, and no duration limit as long as the coverage criteria are met — and Jimmo applies here too, so "not improving" is not a valid reason to end it. Under Medicare Advantage, 90% of enrollees are in plans requiring prior authorization for home health, and plans may impose cost-sharing that Original Medicare does not.

One useful detail: leaving home to receive health care — including regular therapy appointments — does not break "homebound" status. This is frequently misunderstood by patients and occasionally by staff.