a meeting with APTA yesterday, the Centers for Medicare and Medicaid Services
(CMS) clarified the impact of the therapy cap on patients who receive
outpatient therapy services in critical access hospitals (CAHs). CMS stated
that for 2013, when a patient receives outpatient therapy services from a
critical access hospital, the services will count toward dollars accrued toward
the therapy cap. For example, if a patient receives $2,000 of outpatient
therapy services in a CAH and upon discharge goes to a private practice to
continue therapy services, the private practice would need to obtain an
exception (in this case use the KX modifier).
CMS clarified that for 2013 the therapy cap does not apply to outpatient
therapy services provided within CAHs themselves. This means that if the
patient continued treatment in the critical access hospital, after exceeding
$1,900 in therapy services, there would be no need to seek an exception through
the automatic process. That is, the CAH would not need to submit the claim with
a KX modifier. Also, if the patient exceeds $3,700 and continues care in CAH,
the hospital would not need to obtain an exception through the manual medical
had been seeking clarification on this issue from CMS since the January 1
passage of the American Taxpayer Relief Act of 2012 (HR 8), which extended the
current 2-tier therapy cap exceptions process through 2013. The agency advised
APTA last month that it was working with its general counsel for interpretation
of the legislative language.
APTA's comments to the Senate
Finance Committee's May 2012 request for input from health care stakeholders on
3 areas critical to Medicare and Medicaid reforms—program integrity, payments, and enforcement—have
been included in the committee's recently released report
titled "Opportunities to Curb Waste, Fraud and Abuse in Medicare and
the Senate Finance Committee writes about eliminating self referral in 2
sections of the report. Under the Beneficiary Protection section, the committee
notes "concern that over-broad application of the Stark law exception for
physician in-office ancillary services compromises patient care by
incentivizing overutilization." The committee references "increasing
enforcement of existing laws, such as the Stark law" under the area titled
than 160 stakeholders in the health care community submitted comments to the
Senate Finance Committee's request. During the 113th Congress, 6 Senators plan to work
with key committees of jurisdiction, the Government Accountability Office, the
Department of Health and Human Services Office of the Inspector General, and
interested stakeholders to develop a more detailed list of administrative
recommendations and potential legislative actions.
comments can be found on the association's Self Referral webpage.
than 530 physical therapists, physical therapist assistants, and physical
therapy students from Indiana gathered at the statehouse on January 30 to show
their support for HB 1034, which would provide direct access to physical
therapists. Over 50 legislators joined the members of the physical therapy
profession for lunch and to discuss the bill.
Sen Pat Miller and state Reps Dave Frizzell and Matt Ubelhor spoke to the crowd
and confirmed their commitment to passing direct access legislation. Indiana is
1 of only 3 states with no form of direct access to physical therapy treatment,
and the only state without direct access to a physical therapy evaluation. Many
Indiana Chapter members held signs with the messages: "49 states allow you
to see your PT directly … not Indiana" and "Hoosiers deserve direct
access to physical therapists."
House Public Health Committee hearing for HB 1034 will be held February 6. The
chapter is coordinating a team of chapter members to speak in support of the
bill. If it is approved by the committee, the bill would then go to the full
House of Representatives for consideration.
of the January 30 event are available here.
More than 500 organizations will
begin participating in the Centers for Medicare and Medicaid Services' (CMS) bundled payments for care improvement initiative, made possible by the Affordable Care Act. Through this
initiative CMS will test how bundling payments for episodes of care can result
in more coordinated care for beneficiaries and lower costs for Medicare.
The bundled payment initiative
includes 4 models of bundling payments, varying by the types of health care
providers involved and the services included in the bundle. Depending on
the model type, CMS will bundle payments for services that beneficiaries receive
during an episode of care, encouraging hospitals, physicians, postacute
facilities, and other providers as applicable to work together to improve
health outcomes and lower costs. Organizations of providers participating in
the initiative will agree to provide CMS a discount from expected payments for
the episode of care, and then the provider partners will work together to
reduce readmissions, duplicative care, and complications to lower costs through
Last week's announcement includes
the selection of 32 awardees in model 1, who will begin testing bundled
payments for acute care hospital stays as early as April. In the coming weeks,
CMS also will announce a second opportunity for providers to participate in model
1, with an anticipated start date of early 2014.
CMS' announcement also marks the
start of phase 1 of models 2, 3, and 4. In phase 1 (January-July 2013), more
than 100 participants partnering with over 400 provider organizations will
receive new data from CMS on care patterns and engage in shared learning in how
to improve care. Phase 1 participants are generally expected to become
participants in phase 2, in which approved participants opt to take on
financial risk for episodes of care starting in July 2013, pending contract
finalization and completion of CMS' standard program integrity reviews.
list of the model 1 awardees and participants for phase 1 of models 2, 3, and 4
is available on the Center for Medicare and Medicaid Innovation's website.
how physical therapists are getting involved in bundled payment initiatives by
Innovation Summit: Collaborative Care Models. This groundbreaking virtual event will bring
together physical therapists, physicians, large health systems, and policy
makers to discuss the current and future role of physical therapy in integrated
models of care. A panel of experts, moderated by a physical therapist who is
highly involved in bundling initiatives, will provide you with perspectives on
bundling from large health systems, a physical therapy private practice, and
Registration for the Summit
closes Friday, February 8. Interested in attending a viewing party in your
area? APTA will soon list viewing parties and their locations at www.apta.org/InnovationSummit/ViewingParties/.