Monday, September 09, 2013 APTA Recommends Changes to Proposed 2014 Medicare Payment Schedules 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) CMS should not increase the number of required individual measures for successful reporting in 2014 from 3 to 9. Medicare should continue to allow measures groups, such as the back pain measure group, to be reported via claims-based reporting. CMS should not eliminate claims-based reporting in 2017. Medicare should allow measures 126 and 127 (diabetic foot and ankle care measures) to continue to be reported via claims-based reporting. Qualified Clinical Data Registry Requirements CMS should extend the deadline for registries to qualify for 2015 data collection from January 1, 2014, to April 1, 2014. A registry should not have to publically report detailed descriptions on measures under development, as the details might not yet be final. For new registries, the number of measures required for reporting should be 3 instead of 9. Public data reporting should not be required at the outset and should be vetted through a validation process prior to public release. Functional Limitation Data Reporting Recommendations APTA expressed concerns about the absence of 1 standardized tool to measure patient function. Providers should be able to demonstrate patient complexity via use of a modifier such as “low,” moderate,” or “high.” In the future CMS should consider permitting providers to report functional limitation data through other mechanisms, such as registries or electronic health records, in addition to claims. In the acute care hospital setting, CMS should consider exempting from reporting observation status patients and Part A patients rebilled under Part B, as these patients do not exemplify the typical outpatient therapy episode of care. For patients who did not have a formal discharge, CMS should change the episode definition from 60 days from the last date of service to 30 days. ICF categories should be expanded in future years. CMS, APTA, and other key stakeholders should collaborate to develop a standardized core data set for functional limitation reporting. Ultimately, CMS should reform the payment system for outpatient therapy to a per-session system based on severity and intensity. 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.