the Medicare Payment Advisory Commission (MedPAC) voted to adopt several recommendations
on outpatient therapy payment reform. These recommendations will be included in
a report to Congress that may be used to inform future policy related to
outpatient therapy services. Congress has the discretion to determine whether
or not to pass legislation that incorporates any of these recommendations. The
Centers for Medicare and Medicaid Services also can choose to enact MedPAC's
recommendations. APTA will continue to work diligently over the next couple of
months with Congress to extend the exceptions process for therapy services in
2013 and to avoid any payment cuts.
MedPAC commissioners expressed appreciation of the value of outpatient therapy
services for Medicare beneficiaries and recognized that a "hard cap"
with no exceptions would be detrimental and severely impede access to medically
necessary therapy services. Several commissioners also acknowledged that, if
applied appropriately, therapy presents a beneficial alternative to more costly
services, such as surgery and hospital admissions due to falls and other
capping therapy services without an exceptions process, MedPAC recommends that
Congress reduce the therapy cap for physical therapy/speech-language pathology
combined to $1,270 in 2013 and occupational therapy to $1,270 in 2013, and
permanently include hospital outpatient therapy departments under the cap. The
cap amount would be updated each year by the Medicare Economic Index. MedPAC
also calls for the secretary of the Department of Health and Human Services to
implement an improved a manual review process for requests to exceed cap
amounts. MedPAC's recommendation to improve the manual medical review process
was based on what MedPAC staff described as "constructive feedback"
from stakeholder groups, including APTA.
recommendations include applying a multiple
procedure payment reduction (MPPR) of 50% to the practice expense
component of therapy services provided to the same patient on the same day and
reducing the certification period for the outpatient therapy plan of care from
90 to 45 days. MedPAC also voted to direct HHS' secretary to prohibit the use
of V codes as a principal diagnosis on outpatient claims.
improve management of the benefit in the long term, MedPAC recommends that CMS
collect functional status information about beneficiaries using a streamlined,
standardized assessment tool that reflects factors such as patient demographic
information, diagnosis, medications, surgery, and functional limitations. This
information could be used to measure the impact of therapy on functional status
and provide a basis for future long-term reform of the payment system.
In anticipation of
the release of these recommendations, APTA has been aggressively engaged on
Capitol Hill to
ensure payment reforms do not detrimentally impact access, quality, or the
financial viability of providers and facilities that play an essential role in
the health care delivery system.
information, read APTA's October 9 comments to MedPAC regarding its
recommendation to implement a 50% MPPR policy and reduce the therapy cap
amount. Additionally, APTA's comments submitted in September address MedPAC's various long-
and short-term proposals to reform the Medicare therapy benefit.