In comments sent Tuesday to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2013 Medicare physician fee schedule, APTA recommends multiple revisions to CMS' plan for collecting information on beneficiaries' functional limitations as part of payment reform. "While APTA strongly supports gathering information to develop an alternative to the current arbitrary payment limits (or "caps") on Medicare therapy services," the association says, "… CMS's proposal is overly complex and burdensome and may not result in the collection of meaningful and accurate patient information that could be used to develop an alternative payment system."
Following the July 6 release of the proposed rule, APTA immediately began communicating with various stakeholder groups, including the American Hospital Association, the American Occupational Therapy Association, the American Speech-Language-Hearing Association, American Stroke Association, and APTA components about CMS' intention to require therapists to report patients' functional limitations. In a meeting with CMS officials on August 27, APTA urged the agency to keep this particular provision as simple as possible to ensure that the requirements are not excessively onerous for physical therapists and do not cause delays in payment for therapy services.
Specifically, APTA recommends that therapy associations and organizations and CMS collaborate to develop core items in the future that could be used in any tool to standardize data collection. Instead of reporting on primary and secondary functional limitations as described in the rule, APTA recommends that therapists report the information regarding the patient's functional limitation using 1 of 4 specific categories and that CMS establish another G code that would be the "catch all" for functional limitations that do not fit into the 4 categories. Additionally, the association urges against the collection of goal data at this time, comments on the 12-level severity scale, and suggests changes to the proposed frequency of reporting. APTA also provides CMS with a detailed outline of how the agency could implement claims-based therapy data collection in 3 phases that would "decrease provider burden, while still providing CMS with some useful beneficiary information regarding functional limitations."
APTA also remarks on the proposed 27% percent reduction in the Medicare physician fee schedule conversion factor, prepayment review, and the therapy cap. The association comments extensively on the extension and implementation of the Physician Quality Reporting System (PQRS)—voicing its concern over the use of 2013 data to inform the 2015 payment adjustments given the continued low participation rates and overall lack of awareness of programmatic changes to PQRS.