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  • The 2018 Physician Fee Schedule: Where We Are, How We Got Here, What's Ahead

    Here are a few things that can be said about the 2018 Medicare physician fee schedule (PFS) released by the US Centers for Medicare and Medicaid Services (CMS):

    1. It's a mixed bag in terms of adjustments to current procedural terminology (CPT) codes commonly used in physical therapy, with some values going up, and others being cut.
    2. Physical therapy isn't the only profession that saw CPT code reductions: otolaryngologists, nurse anesthetists, and urologists, to name a few, are also bracing for cuts.
    3. It could've been a lot worse—up to a 10% cut or more based on changes to the practice expense.
    4. Statements 1-3 aren't much consolation when you're a physical therapist (PT) facing estimated average payment reductions between 1.3% and 2% (but again, this is hard to pinpoint: there will be increases, but in other cases decreases will be even worse).

    What happened?
    Just a few months ago, the outlook was good for PTs when it came to next year's PFS. After a 2-year American Medical Association analysis of CPT codes that CMS believed may have been potentially "misvalued," the proposed rule that emerged was a clear win for the profession: no cuts to codes values, and even a few increases. From the perspective of the profession, the proposed rule adopted all of the positive recommendations from AMA—namely, no cuts and a few increases to work relative value units (RVUs)—and none of the damaging AMA recommendations, which included adjustments to practice expense (PE) inputs that would affect payment. Things were looking good, and APTA and its members advocated strongly for the rule as proposed.

    When the final rule was issued in November, things stopped looking so bright. Between release of the proposed rule and publication of the final version, CMS veered away from its typical process when it announced—without warning and without allowing opportunity for input from any stakeholders, including APTA—that it would reverse its decision and adopt the recommendations related to PE inputs. The rule change has altered the payment landscape for PTs in ways that are still being worked out by APTA. The association has published a summary of the rule on its website (listed under "APTA Summaries and Fact Sheets").

    Mapping the landscape
    While it's true that the final rule will result in increases in some areas, some of the payment reductions that will go into effect next year will hit home for some PTs. What is known for certain is that a few of the most commonly used codes in physical therapy will see a drop, including manual therapy, therapeutic exercise, mechanical traction therapy, and aquatic therapy.

    At the same time, other codes will increase—some significantly. Gait training therapy values will increase, as will neuromuscular reeducation, and therapeutic activities. Values for the 3-tiered evaluation codes adopted by CMS in 2016 also will rise (although the single value for all 3 tiers is maintained), in addition to orthotic management and training (first encounter), and prosthetic training (first encounter).

    APTA is putting final touches on a calculator that will help members get a more precise estimate of the potential impact of the new rule, given their particular practice circumstances. The calculator is set to be released early next week.

    "While it's clear that the CMS reversal from its proposed rule will result in drops to some of the codes used frequently by PTs, the bottom line effects of the new rule will vary depending on case mix and billing patterns," said Carmen Elliott, MS, APTA vice president of payment and practice management. "The overall 2% drop estimated by CMS doesn't take that variation into account. There will be some providers who will see reductions in payment of anywhere from 1% to 2%, but we anticipate that others could see overall increases."

    How we got here
    "This is frustrating, both in terms of the payment reductions as well as the way CMS surprised stakeholders with its reversal from the proposed rule. The cuts will be hard on some physical therapist practices," said APTA Vice President of Government Affairs Justin Elliott (no relation to Carmen Elliott). "It’s also true that the initial projections, long before the initial proposed rule, were far more bleak."

    Justin Elliott is referring to the way CMS handles codes that it believes may be "misvalued"—often read as a euphemism for "overpaid." It's a complex, multi-year process overseen by the AMA's Relative Value Scale Update Committee (known as RUC) Health Care Professions Advisory Committee (HCPAC). The RUC HCPAC engages in dialogue with stakeholder groups, including APTA, and conducts surveys of individual providers before issuing recommendations on how codes should be valued. The survey of PTs was conducted in October 2016.

    When the process began in early 2016, indications were that, overall, CPT codes commonly associated with physical therapy could see a double-digit cut. APTA staff and CPT advisors worked with the RUC HCPAC to move recommendations away from that potentially catastrophic change, and survey responses from PTs helped to reinforce the notion that current code values were not far off—at least in terms of averages across all codes.

    Given where things seemed to be headed in 2016, the release of the final rule, though far less than ideal, does amount to a win—of sorts. And context is important: physical therapy wasn't alone in professions with codes on the CMS chopping block, with otolaryngologists, anesthesiologists, nurse anesthetists, urologists, and vascular surgeons all seeing overall code reductions between 1% and 2%, according to CMS estimates.

    What's next?
    According to Justin Elliott, "APTA is exploring all avenues to advocate against these cuts before they take effect on January 1, 2018." He added, "All options are on the table and every path is being evaluated for our response to the final rule."

    Those advocacy efforts will require APTA and its members to have a solid understanding of just how the CPT changes impact them during the coming year, according to Carmen Elliott, who said that the key to getting insight on the effects is for PTs to continue to code and document appropriately while they evaluate their case mixes and other factors. "The only way to truly understand the effects of these changes is for our coding efforts to remain consistent," she said.

    At the same time, APTA President Sharon Dunn, PT, PhD, thinks there's an even bigger picture to be considered.

    "We can't yet say what the overall impact will be as a result of these code value changes, and we know that the effects will vary from provider to provider," Dunn said. "What we can say for sure is that these kinds of adjustments and recalculations truly underscore the need for health care providers to move toward value-based payment models that truly reflect the value of physical therapist services’ triple aim—improving the experience of care, improving population health, and reducing costs. The CPT code structure has 1 foot firmly planted in the outmoded fee-for-service world. That needs to change."

    Comments

    • I cannot fathom the philosophy of reducing reimbursement for manual therapy and therapeutic exercise. The basis of what we do.... they obviously have no idea about what PTs do and the value of our service within the healthcare community. So sad and disgraceful.

      Posted by Tracy Urvater on 11/18/2017 2:22 PM

    • CMS is making it difficult for physical therapists to work as physical therapists. We are hands on people and so there will come a time when we are no longer able to accept Medicare clients. They are typically the population most in need of our hands on manual skills.

      Posted by Kevin Lacey on 11/22/2017 2:50 PM

    • With the 2020 vision coming to near completion, it is incomprehensible that the exact opposite is happening in the realm of reimbursement. Our PTs are becoming more and more educated and demanding higher and higher salaries. This is something the APTA must strongly investigate or the future of PT will be forever compromised.

      Posted by Lisa on 11/22/2017 5:23 PM

    • I can't see 1-2 % being the father that breaks the camel's back with MediCare. With what they already don't pay and the multiple procedure payment reduction crap they're already pulling. What's 2% of nothing again?

      Posted by Leon Richard on 11/22/2017 6:47 PM

    • What’s worse is that in 2018, massage therapy will pay more than manual therapy.

      Posted by Rick Gawenda on 11/22/2017 8:15 PM

    • I have been an APTA member since 1993 and have face contant cuts in growing increase in paractixe expense especially the digital training costs due to software issue increased coat of living requiring increased salaries what IS THE APTA doing for me it ia time to unionize healthcare and push back against the insurance industry facing a pay cut every year is ludicrous So much I am thinking of closing my practice and turning it into a discount store can make more the red tape is sickening we work ourselves to death with compliance WHO IS PAYING FOR THAT? Who is working for us because whomever it iis not getting it done if all we do is face a pay reduction year after year the cost of operations and living us way up Call for union Annare L Loubser PT DPT OCS CFMT

      Posted by Annare LoubserPT on 11/24/2017 6:30 PM

    • with the big push to get people off opiates etc etc, and now they are cutting two of the codes that we use the most to help these people, why would we proceed in this direction. It seems that the education of what PTs do and what our philosophy is has been lost esp. with manual therapy. Soon our profession will be like teachers, the best minds will go to other professions bc we have been priced or chopped out of existence as education gets more and reimbursement gets less. SHAMEFUL.

      Posted by Eric on 11/27/2017 11:18 AM

    • My concern is that as PTAs gain autonomy, they will replace PTs especially in MD offices, nursing homes, etc. As PTs become more highly educated, it is cost effective to use PTAs without significant PT supervision. overall a BAD idea

      Posted by Judy Hurley on 11/29/2017 2:40 PM

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