The therapy cap and its application to critical access hospitals, PQRS, incident-to billing, MPPR, functional claims-based data collection, and OPPS adjunct bundling services are among the issues APTA addressed in comments last week to the Centers for Medicare & Medicaid Services (CMS). The comments were in response to Medicare's 2014 payment proposals for the physician fee schedule (View APTA comments.), clinical laboratory fee schedule, other revisions to Medicare Part B payment, and the hospital outpatient prospective and ambulatory surgical center payment systems (OPPS) (View APTA comments.).
The full comments are posted on www.apta.org and highlights are summarized below.
For the physician fee schedule, clinical laboratory fee schedule, and other revisions to Part B for 2014, which were announced July 19, APTA made these recommendations:
Critical Access Hospitals (CAHs)
CMS should not permanently apply the therapy cap to critical access hospitals. CMS can and should continue to interpret congressional intent to treat hospitals and CAHs in the same manner in the application or nonapplication of the therapy caps.
Multiple Procedure Payment Reduction (MPPR)
CMS should mitigate the impact of the MPPR cuts, including no longer applying the MPPR across multiple therapy disciplines and working with Congress on long-term reform of the payment system.
Incident-to Billing Provisions
CMS should ensure that its proposal requiring individuals who perform incident-to services to meet state requirements is included in the final rule.
Physician Quality Reporting System (PQRS)
Qualified Clinical Data Registry Requirements
Functional Limitation Data Reporting Recommendations
For OPPS, APTA recommended that CMS remove physical therapy services provided by qualified physical therapists and physical therapist assistants from the list of potential adjunctive services included in the new 29 comprehensive APCs. APTA also recommended the removal of the direct supervision requirement for outpatient therapeutic services in CAHs under OPPS because it is burdensome, unnecessary, and not based on clinical need.
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