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  • Proposed 2014 Physician Fee Schedule Adjusts Payment Rates, Updates PQRS, Applies Therapy Cap to CAHs

    Today, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2014 Medicare physician fee schedule rule that updates 2014 payment amounts and revises other payment policies. Excluding the 24.4% projected sustainable growth rate payment cut, the rule’s aggregate impact on payment is a positive 1% for outpatient physical therapy services. Additional proposed policies that will impact physical therapists include updates to the Physician Quality Reporting System (PQRS) program, application of the therapy cap to critical access hospitals, and changes to the calculation of geographic practice cost indices.

    The law applies an annual beneficiary limit on outpatient therapy services for physical therapy and speech-language pathology services combined and a separate limit for occupational therapy services. Following the passage of the American Taxpayers Relief Act earlier this year, outpatient therapy services provided in critical access hospitals (CAHs) accrued toward the therapy cap amount for the first time. However, in 2013 CAHs are not subject to the therapy cap, meaning they currently do not have to report the KX modifier when the cap is exceeded or undergo manual medical review for services exceeding $3,700. The proposed rule would change this policy to apply the cap to outpatient therapy services furnished in CAHs in 2014 if Congress extends the therapy cap provision to hospitals in 2014.

    CMS proposes to retain the 12-month calendar year reporting period for the PQRS program in 2014 and beyond. The incentive payment for 2014 will remain 0.5%. The 2014 reporting period data will be used to inform both the 2014 incentive payment (0.5%) and the 2016 payment adjustment (-2.0%). CMS is proposing to make the following changes to the successful reporting requirements for 2014:

    • Increase the number of measures that must be reported via the claims and registry-based reporting mechanisms from 3 to 9
    • Change the threshold for reporting individual measures via registry to require that eligible professionals report on 50% of the eligible professional’s applicable patients rather than 80%
    • Eliminate the option to report on claims-based measures groups

    The proposed rule will be published in the July 19, 2013, Federal Register. The public will have until September 6, 2013, to submit comments in response to this rule, and APTA will submit comments on behalf of its members. After reviewing public comments, CMS will publish a final rule on or about November 1, which will become effective for services furnished during calendar year 2014. APTA will provide a more detailed summary of the rule in the upcoming week.


    • Change PQRS Measures required from 3 to 9??? On top of FLR? Wouldn't it be grand if our therapists were able to spend their time actually treating patients? More and more therapists are being forced to purchase products to assist them with these additional requirements, combined with deep pay cuts (MPPR) I wonder just how much more they can take?

      Posted by Cheri Freeman on 7/9/2013 7:52 AM

    • I don't understand the need to increase the number of measures reported from 3 to 9. We are already spending precious treatment time collecting and submitting data for PQRS and FLR. Adding an additional six measures is unreasonable and will impact patient care. I am all for objective functional measures and evidence based treatment but not to the point where it infringes upon the time I spend with my patients.

      Posted by Corinne Holmes -> =HW[=L on 7/9/2013 11:32 AM

    • The last paragraph of the PQRS update from CMS seems to imply that we only need to report 3 measures at 50% to avoid the 2016 payment adjustment. We don't need to report 9 measure to avoid the 2% penalty. We need to report 9 measures for the 0.5% bonus. Do you interpret this the same way? "We are proposing that if an EP meets the criteria for the 2014 PQRS incentive, this will serve to satisfy the reporting for the 2016 PQRS payment adjustment (in other words, EPs who meet the criteria for the 2014 PQRS incentive will automatically avoid the downward payment adjustment for 2016). In addition, we are retaining the criterion established in the CY 2013 PFS final rule that an EP using the claims-based reporting mechanism may report 3 measures on 50% of the eligible professional’s applicable patients for the 2016 PQRS payment adjustment." http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-Sheets/2013-Fact-Sheets-Items/2013-07-08-2.html

      Posted by Marty Ugarte, CPC on 7/9/2013 11:56 AM

    • Thank you for sharing your views regarding the proposed changes to the PQRS program included in the physician fee schedule rule. This is a proposed rule and therefore is open for public comment until September 6, 2013. The rule will be finalized November 1, 2013 after CMS reviews the public comments and makes modifications. As APTA develops comments in response to the rule, your feedback is very helpful. If you have additional comments that you would like to share with APTA on this rule, please email us at advocacy@apta.org

      Posted by News Now Staff on 7/9/2013 2:59 PM

    • You cannot have quality outcomes if you spend 1/2 the session reporting on quality outcomes. Time with the patient is the way to get quality outcomes. PQRS and FLR need to be linked not separate reporting, or PQRS needs to be dumped and just do FLR. "It's all about function" and yet we are reporting on drug interactions and BMI that may or may not be impacting function. Just report function, or attach a flat administrative payment to the fee schedule to take care of the extra cost incurred by the practices to report these outcomes in CMS mandated formats.

      Posted by Daniel Headrick on 7/10/2013 4:15 PM

    • 3 measures is already difficult to document on. I can't imagine 9. I agree PQRS and FLR should be linked.

      Posted by Sara Oxborough on 7/12/2013 3:42 PM

    • It's depressing to watch my profession become less and less about quality patient care and more about properly doing my paperwork. I am concerned that more therapists may decide to no longer take medicare (as many physicians in my area are) or to completely leave our profession. I must admit that the load we are carrying in light of lower reimbursements and more demands on our limited time have me looking for other ways to use my skills. Carolyn Packard, MPT

      Posted by Carolyn Packard on 7/12/2013 4:16 PM

    • While I agree that capturing useful medical information for risk factors in an elderly population is advantageous, I wonder if the consumers seeking therapy have been asked what they think? We could incorporate the necessary measures over the course of care once we have identified potentials for risk i.e. falls. Including 9 measures at the initial visit would result in assessment only. If that is needed, perhaps that is how we should be compensated.

      Posted by Debra Q Virtanen, PT, MS, DPT on 7/13/2013 6:02 AM

    • Figures. Each year I expect Medicare to keep reducing our payments and increasing requirements up to the point where a number of providers elect to drop Medicare.

      Posted by Greg Given on 7/13/2013 10:56 PM

    • To Carolyn Packard and other PTs - wish we could decide to stop taking Medicare...but we PTs can't opt out like other professionals....I even called Medicare and asked if we leave clinic setting and set up a room with one table and nothing else are we still considered providers and how about treating a patient in the back yard...answer was Yes..have to bill Medicare if they are a Medicare patient no matter what...this is getting ridiculous! Let's

      Posted by Nancy Dewey on 7/15/2013 6:49 PM

    • I am glad I am near the end of my career rather than just starting it. It is hard enough to give quality treatment in limited time and limited visits as it is without more documentation and justification requirements taking their bite out of our evaluation and treatment times. I do not even want to imagine what the future holds if this trend continues.

      Posted by Cheri Lenhart MSPT on 7/15/2013 8:17 PM

    • The absurtity of the increasing amounts of paperwork is astounding. Do they really want us to treat patients at all, or are they really only concerned about paperwork and justifying their positions?? I got into PT to actually do PT, not paperwork. I used to spend 10-15 minutes 10 years ago for a half day, now I spend 30-45 minutes of unpaid time. Really? Isn't socialized medicine a good thing? NOT. Who does CMS think is going to treat all their patients when PTs finally say enough and decline seeing Medicare patients? I don't think they have thought that though?

      Posted by Chris on 7/22/2013 9:53 AM

    • Not only is the proposal to expand from 3 to 9 measures burdensome they are also proposing to (eventually) move to Registry only submission ($$). This is truly healthcare bureaucracy at it's absolute worst.

      Posted by Rob on 7/25/2013 2:14 PM

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