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  • Therapy Cap Resources Now Available

    On Wednesday, President Obama signed the Middle Class Tax Relief and Job Creation Act of 2012 (HR 3630), extending the therapy cap exceptions process for the remainder of 2012. The law mandates consistent use of the KX modifier upon reaching the $1,880 therapy cap and puts in place several reforms to the therapy cap policy.

    Starting October 1, claims that meet or exceed $3,700 in annual therapy expenditures will be subject to a manual medical review. The $3,700 threshold will be applied to the combined physical therapy/speech-language pathology cap; a separate $3,700 threshold will be applied to the occupational therapy cap. Also starting October 1, each request for payment must include the national provider identifier of the physician who currently periodically reviews the plan of care. Additionally, HR 3630 designates that the therapy cap along with the exceptions process should apply to the hospital outpatient setting no later than October 1. This provision, along with the full exceptions process, will expire at the end of 2012 unless Congress chooses to extend them into 2013.

    An information bulletin, podcast, and FAQs thoroughly outline these new provisions and also address 2 key reports mandated by the law to review methods to improve the outpatient therapy benefit and examine the manual medical review process.

    CMS Releases Stage 2 Requirements for EHR

    Yesterday, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for Stage 2 criteria for "meaningful use" for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.

    In the rule, CMS proposes to specify criteria that eligible health care professionals (EPs), eligible hospitals, and critical access hospitals must meet in order to qualify for an incentive payment, as well as introduce changes to the program timeline and detail payment adjustments. The proposed Stage 2 criteria focus on increasing the electronic capturing of health information in a structured format and the exchange of clinically relevant information between providers at care transitions.

    CMS also proposes new objectives that have greater applicability to specialty providers and additional criteria for reporting clinical quality measures.

    Physical therapists (PTs) are not defined as EPs at this time; therefore, they are not yet eligible for incentives under Medicare of Medicaid, but, accordingly, they will not be subject to penalties for failure to implement EHR systems. However, physicians and facilities that are included in the program will expect PTs with whom they share patients to use compatible EHR systems. A new APTA resource, Guide to Understanding and Adopting Electronic Health Records, can help PTs make decisions about selecting and implementing EHRs.