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  • The Hard Therapy Cap Is Here: Answers to Some Common Questions

    Because of inaction by Congress, the hard cap on outpatient therapy services under Medicare has been implemented. The cap, which began on January 1, 2018, includes no KX modifier exceptions and has created uncertainty for providers, patients, and their families.

    APTA has requested that the US Centers for Medicare and Medicaid Services (CMS) provide information and guidance for providers on how the (temporary, it is hoped) hard cap will be managed. While the association waits for that response, here are a few questions and answers that shed some light on where things stand.

    What is the therapy cap for calendar year 2018?
    The allowed dollar amount for 2018 for outpatient physical therapy and speech-language pathology combined is $2,010. For occupational therapy, the cap is set at $2,010.

    What Part B outpatient therapy settings and providers does the therapy cap apply to?

    • Physical therapists' (PTs') private practices
    • Offices of physicians and certain nonphysician practitioners
    • Part B skilled nursing facilities
    • Home health agencies (visits provided on an outpatient basis)
    • Rehabilitation agencies (also known as outpatient rehabilitation facilities)
    • Comprehensive outpatient rehabilitation facilities
    • Critical access hospitals (CAHs)

    What is the targeted medical review threshold for 2018?
    With the implementation of the hard therapy cap on January 1, 2018, there is no targeted medical review threshold. This is subject to change, pending congressional action.

    Does the 2018 hard therapy cap apply to hospital outpatients?
    No. Hospital outpatient departments or clinics (OPs) were not originally included under the therapy cap when it was first enacted as part of the Balanced Budget Act in 1997. That exclusion was lifted when hospital OPs were added to the manual medical review process in 2012. Later, hospital OPs were regularly made subject to the cap as part of the stopgap exceptions routinely enacted by Congress. But in 2017, Congress not only failed to end the hard cap; it failed to create an exceptions process of any kind, meaning we're back to the hard cap as originally written, which doesn't include hospital OPs.

    Does the hard therapy cap apply to observation-status patients in hospital outpatient departments?
    No. The hospital setting is not included under the hard therapy cap that went into place on January 1, 2018 (see hospital outpatient question above). Hospital outpatients include those in observation status. Therapy services furnished to patients on observation status are billed as outpatient therapy services under Medicare Part B; however, because the hospital setting is not included under the hard cap, observation status patients are excluded.

    Does the hard cap apply to Critical Access Hospitals?
    Yes. Before October 1, 2012, the therapy caps applied to all outpatient therapy services except those furnished by outpatient hospitals and CAHs. Beginning January 1, 2014, the outpatient therapy caps, and related provisions, were applied to therapy services furnished by a CAH. Therapy services furnished by a CAH are counted toward the therapy caps as if the services were paid under the Medicare physician fee schedule.

    When are therapists required to issue the mandatory Advance Beneficiary Notice (ABN) for therapy services?
    Providing the patient with an ABN transfers liability and charge to the beneficiary, and becomes a crucial duty of the therapist now that the no-exceptions cap is in place. Providers must issue a valid, mandatory ABN to the beneficiary before providing services above the cap when there is no therapy coverage exceptions process. Therapists also are required to issue the ABN to original (fee-for–service) Medicare beneficiaries before providing therapy that is not medically reasonable and necessary.

    Wasn't Congress ready to permanently end the hard cap? What happened?
    It's true: over the fall, a bipartisan, bicameral deal was reached that would have permanently eliminated the hard cap on therapy services. That deal was part of a larger piece of legislation that included other changes to Medicare, such as payments for ground ambulances and reauthorization of special needs plans. This package of so-called "Medicare extenders" was supposed to be adopted in early December. Unfortunately, the debate over the tax reform legislation dominated Congress in the final weeks of session, pushing nearly all other issues to 2018.

    What happens next?
    The Senate returned to Washington on January 3, and the House will return on January 9. The first opportunity to address the hard cap will come when Congress takes up a spending bill that must pass in order to keep the government open after January 19. There are also opportunities for the cap repeal to be included in any of a number of other critical health care programs that expired on December 31, which Congress must act on immediately. Unfortunately, there are no sure bets: given the current political climate in Congress, including other unrelated, controversial issues in play, it is unclear if Congress will act quickly. APTA, the American Occupational Therapy Association, the American Speech-Language-Hearing Association, and other allies in the Therapy Cap Coalition will continue to keep pressure on Congress to take quick action on the therapy cap in January.

    Will Congress retroactively apply any fix to the Therapy Cap back to January 1, 2018?
    Nothing is certain at this point. APTA and its partners are asking Congress to apply any fix retroactively to January 1, 2018.

    What can I do?
    It's important for the physical therapy profession to advocate for this critical permanent fix to the therapy cap. Contact your members of Congress today via email, phone, and social media, and urge them to pass the therapy cap permanent fix as soon as possible. Visit APTA's Medicare Therapy Cap webpage for more information, download the APTA Action App to keep up-to-date on action alerts, and be sure to stay tuned for additional updates.

    Get the Latest on the Future of Payment—And the Now of Home Health

    Are you ready for the future of payment—both near-term and down the road? APTA is ready to help you stay up to speed.

    The association offers 2 opportunities to learn about the payment landscape in 2018 and beyond: one focused on the bigger picture and another that zeroes in on changes to home health services.

    For the big picture, be sure to sign up for "The Shift to Value-Based Payment: What You Need to Know Now," a live webinar set for January 18, 1:00 pm–2:00 pm EST. The interactive session, led by APTA staff experts, will focus on participants' questions on what Medicare's shift toward value-based payment means for providers. The program is configured as a "flipped classroom"—participants need to register in advance, review a prerecorded presentation, and be ready for live interaction at the actual session. Best of all, it's free to APTA members.

    PTs and PTAs looking for more specific information on changes to home health rules can download an audio recording of a December 11, 2017, webinar focused on new home health conditions of participation set to go into effect January 13, 2018. The session, conducted by APTA staff and representatives from APTA's Home Health Section, sheds light on the practice implications of the new participation rules. And like the January 18 webinar, it's free. To download, visit APTA's Medicare Payment and Policies for Home Health webpage and click on the "Webinar Recording" link dated 12/11/17.

    Humana Lifts Prior Authorization Requirements for Physical Therapist Services

    Physical therapists (PTs) and patients may face plenty of challenges when it comes to dealing with private insurers, but for those who participate in the Humana system, preauthorization for physical therapy is no longer one of them. In a move strongly supported by APTA, the insurer lifted the prior authorization requirement for outpatient physical therapy, occupational therapy, and speech-language pathology.

    Humana made the announcement earlier this month, stating that the change was effective December 18, and applies to both commercial and Medicare Advantage policies. Other elements of the Humana benefit package remain unchanged, including visit limits, referral requirements for some plans, and medical necessity requirements. Prior to the change, PTs, occupational therapists, and speech-language pathologists were required to obtain preapproval from a utilization management/review vendor.

    APTA has long advocated for the elimination of prior approval as a much-needed change for patients and providers, but also as a way for the association and the insurer to demonstrate how more collaborative relationships can improve the health care landscape.

    "This is great news for patients and PTs," said Elise Latawiec, PT, MPH, APTA senior practice management specialist. "But this change also presents an even bigger opportunity. When we demonstrate how the elimination of prior authorization can reduce administrative burdens on PTs, decrease overall costs, and improve outcomes in the Humana system, we build an even stronger case that we can make to other insurers with prior authorization requirements. As a profession, we are committed to being responsible stewards of limited health care resources, and can show that we can be held accountable without the use of an intermediary gatekeeper."

    Providers working with Humana can get more detailed information on the change by contacting the Humana telephone number listed on a patient's member identification card.

    The Humana decision represents a reversal in a trend toward greater use of utilization management (UM) vendors among insurers. APTA works to keep its members informed on the UM environment through an online toolkit that debuted in 2017. The association is also bringing the profession's voice to the table by participating in various payer and utilization management advisory groups.

    Inaction by Congress Triggers No-Exceptions Therapy Cap in 2018

    In a development that leaves patients and providers in the lurch, Congress has recessed without addressing the Medicare therapy cap in any meaningful way. The inaction is particularly disappointing for APTA and other stakeholders given that a bipartisan agreement had been reached to permanently end the hard cap.

    The bottom line: beginning on January 1, 2018, the $2,010 hard cap on physical therapy and speech-language pathology services combined will be instituted, and the exceptions process that currently permits medically necessary services above the cap through use of the KX modifier will no longer apply.

    In late October, Congress seemed poised to enact a permanent repeal of the hard cap and included that change in a package of Medicare "extenders." Had those extenders been approved, it would have ended Congress' continual tradition of late-year scrambling to come up with a short-term exceptions process. Instead, Congress recessed without approving the extenders or enacting a temporary exceptions process.

    Over the past several months, thousands of APTA members called and tweeted their members of Congress, and generated over 20,790 emails to Capitol Hill urging Congress to pass the permanent fix for the therapy cap

    "Congress’ inaction creates the worst-case scenario for patients and providers," said APTA President Sharon Dunn, PT, PhD. "Medicare patients will start the new year unsure if they will receive medically necessary care. This inaction by Congress means arbitrary barriers, stress for patients and their families, and disruptions for providers."

    The therapy cap is just 1 of several issues left unresolved by Congress. A number of other critical Medicare extender policies that needed action, but also will now expire on December 31, include everything from special payments for ground ambulances, to reauthorization of special needs plans, to an extension of the State Health Insurance Health Programs.

    There is a chance the cap could be short-lived. Congress returns from its recess on January 19, and APTA’s congressional advocates and other patient and provider groups that are part of the Repeal the Therapy Cap Coalition will work to get the bipartisan agreement included in the next "must-do" bill to be taken up.

    "Congress is well aware of the negative ramifications of the therapy cap, which is why there is bipartisan support to repeal it," said Justin Elliott, APTA's vice president of government affairs. "It is imperative that Congress take action as soon as possible in January, and we will keep up the fight."

    APTA also will provide additional information and resources to help practitioners prepare for the application of the hard cap on January 1.

    APTA Urges CMS to Consider Ripple Effects of Medicare Advantage Changes for 2019

    Efforts by the US Centers for Medicare and Medicaid Services (CMS) to make Medicare Advantage (MA) plans more accessible to more vulnerable beneficiaries are laudable, and provisions that would steer patients away from overuse of drugs are understandable, but CMS needs to be mindful of the unintended consequences of these and other changes, says APTA in its comments on proposed MA rules changes for 2019.

    At the center of APTA's comments are proposed changes to so-called "uniformity requirements," out-of-pocket limits, and frequently abused drugs. Essentially CMS would like to make it easier for more vulnerable individuals to participate in MA plans by reducing cost-sharing requirements, and harder for providers and patients to overutilize certain drugs, including opioids. Both efforts are worth pursuing, APTA says in its comments to CMS.

    However, the association adds, those efforts need to be balanced against other concepts in MA plans.

    Specifically, APTA warns CMS that healthier members of the MA population shouldn't shoulder the expense of increasing access for more vulnerable individuals who want to participate through increased cost-sharing on services such as those provided by a physical therapist. The association also encourages CMS to require Medicare Part D sponsors to provide beneficiaries with more information on nondrug treatment options, increase access to those options, and support interdisciplinary care for treatment of chronic pain and opioid addiction. APTA's comments can be accessed on the association's Medicare Advantage webpage.

    The call for comments on proposed MA changes is an annual event, explained Kara Gainer, APTA's director of regulatory affairs, but as the program grows with every passing year, the provisions are beginning to play a bigger part in the overall health care landscape.

    "More and more Medicare-age beneficiaries are enrolling in Advantage plans, so now is the time for CMS to implement policies that ensure access to physical therapy," Gainer said. "But in addition to making changes that improve that access, CMS needs to make sure it maintains the gains we've already made."

    President Signs Law Allowing PTAs in TRICARE; Implementation May Not Be Immediate

    Physical therapist assistants (PTAs) are on their way to officially joining the TRICARE payment program used throughout the Department of Defense (DoD) health care system. President Donald Trump's signature on the National Defense Authorization Act enacts a change long advocated by APTA, but what happens next isn't entirely clear.

    One thing that's certain: the change won't take effect immediately. APTA Senior Congressional Affairs Specialist Michael Hurlbut says PTAs should keep themselves updated on the progress of implementation.

    "This is a huge step forward for PTAs, but the law itself simply directs DoD to make the change—it will take some time for actual regulations to be created and put in place," Hurlbut said. "APTA staff are monitoring progress, and will keep members informed of the timeline for the changeover to the expanded TRICARE system."

    The first glimmers of a possible change in TRICARE came in June 2017, when a US House of Representatives committee requested that the Secretary of Defense come up with a plan for bringing PTAs, occupational therapy assistants, and other support personnel into the TRICARE system. From there, action on the idea moved relatively rapidly from the House to a Senate committee, and then on to a vote in the full Senate in November.

    "We're very pleased that this APTA-backed change has been achieved," Hurlbut said. "This addition will make a difference for patients in TRICARE who deserve access to the valuable services provided by PTAs."

    New Webpage Maps APTA's Coalition Connections

    "Better together"—the idea that more gets done when everyone's pulling in the same direction—has been a key theme within APTA for a few years now. But the association extends that idea far beyond its own members and components, and now you need look no further than a new APTA webpage for proof.

    Now available at APTA.org: a new resource that lists the coalitions, alliances, and other shared interest groups in which the association participates to help highlight important issues and bring the profession's voice to the table. The listings are grouped as "advocacy," "payment," and "practice," and include links to the coalitions themselves whenever possible.

    It's not a short list. As of the publication of the page, APTA lists no fewer than 30 groups in which it has involvement, including the Therapy Cap Coalition, the Coalition to Preserve Rehabilitation, the Disability and Research Rehabilitation Coalition, the Joint Commission, and the Academy of Nutrition and Dietetics, to name a few.

    The association's involvement in shared interest groups has played a significant role in some clear gains for patients and the physical therapy profession, including the Alliance for Integrity in Medicare Coalition's work in debunking of the "improvement standard" myth brought to light through the Jimmo v Sibelius settlement agreement, and the National Physical Activity Plan Alliance efforts to focus attention on the importance of physical activity as a way to improve public health.

    Want more information on APTA's involvement in other groups? Email advocacy@apta.org or practice@apta.org.

    APTA Fact Sheets on 2018 Outpatient Payment, Home Health Now Available

    Now available to APTA members: context and details to help you understand final 2018 rules from the Centers for Medicare and Medicaid Services (CMS) on the home health (HH PPS) and outpatient (OPPS) prospective payment systems.

    The final OPPS rule includes provisions that APTA supported—particularly moves toward reimbursement for outpatient-based total knee arthroplasty (TKA) and "non-enforcement" of direct supervision requirements for outpatient therapeutic services delivered in designated critical-access hospitals and rural hospitals with fewer than 100 beds. The rule also includes an overall 2% payment increase for outpatient hospitals and a 1.9% boost for ambulatory surgical centers. To access the fact sheet, visit the APTA Medicare Payment and Policies for Hospital Settings webpage. Scroll to the "Outpatient Care" area and look under "APTA Fact Sheets and Summaries."

    After receiving significant opposition from APTA, the APTA Home Health Section, and other professional and consumer advocacy organizations, CMS backed off on a proposed rule to adopt a payment system that, among other changes, would have removed therapy service-use thresholds from the payment mix. For now, CMS plans to leave the payment system as-is for the most part, but the agency will use 2018 as an opportunity to explore changes with stakeholders. In terms of payment amounts, CMS will enact an $80 million reduction in 2018, a cut mandated by the Affordable Care Act. The APTA fact sheet can be accessed on the association's Medicare Payment and Policies for Home Health webpage, under "APTA Fact Sheets and Summaries."

    Want even more information on CMS-related changes in store for 2018? Don't miss the December 13 Insider Intel call-in program that will include information on HH PPS and OPPS provisions. The program is available at no cost to APTA members.

    4 Things to Do Now That the 2018 Fee Schedule Is Out

    By now, most physical therapists (PTs) have heard the news: the final 2018 Medicare Physician Fee Schedule (PFS) released in early November by the US Centers for Medicare and Medicaid Services (CMS) included some significant variations from the PFS proposed in July. Instead of finalizing CPT code values that were the same as—and occasionally larger than—current values, CMS opted to offer up a more complicated combination of cuts and increases that could affect PTs in different ways, depending on their case-mix and billing patterns.

    So what should PTs do in the wake of the new PFS? Here are APTA's top 4 suggestions.

    1. Know the design process for the fee schedule.
    It's important to understand what led to the changes to provide context, a slight sense of relief, and a reminder of why payment needs to move toward value-based models and away from fee-for-service.

    The PFS now set to debut January 1, 2018, is the CMS response to an American Medical Association (AMA) committee's recommendation on potentially "misvalued" codes associated with a wide range of professions, not just physical therapy. When the process began in early 2016, many predicted that the final outcome would be deep cuts to nearly all valuations—as much as 10% or more overall. APTA and its members fought hard to substantiate the validity of the current valuations, and even the need for increases in some areas. The end result was a significant improvement from where things were headed at the start of the process.

    That's not to say it's been an entirely satisfying process from start to finish. This recent PT in Motion News story goes into more detail about the sometimes-frustrating journey from points A to B.

    2. Understand what's being changed.
    Just about everything that happens at CMS is complicated, and the process that led to the new CPT code valuations is no exception. Still, a working knowledge of how CPT codes are valued is helpful in understanding why the PFS contains such a mix of positives and negatives.

    One important thing to understand is that code valuation is actually a stew of 3 separate elements, known as relative value units (RVUs). These are estimations of the labor, expense, and possible professional liability involved in performing any given treatment or evaluation task associated with a CPT code. The 3 types of RVUs are known as "work," "practice expense" (PE), and "professional liability." The coding valuation differences between the proposed and final PFS were due to changes to the PE RVUs only.

    This wasn't part of the proposed rule. While the AMA Relative Value Scale Update Committee Health Care Professions Advisory Committee did recommend changes to PE RVUs, CMS initially opted to not adopt those suggestions. When the final rule was released 3 months later, CMS—without seeking input from APTA or any other stakeholders—did an about-face and adopted the changes to PE RVUs.

    So what? The answer is twofold: first, the tweaks to PE RVUs mean it's difficult to make many sweeping generalizations about how the new PFS will affect individual practices and clinics; second, it's worth noting that individual work RVUs either remained unchanged or increased.

    A more detailed explanation of how the codes were affected is available in an APTA fact sheet on the 2018 PFS (listed under "APTA Summaries and Fact Sheets"). For a more complete explanation of RVUs and the differences between the 3 types, check out this APTA podcast on the CPT valuation process.

    3. Get a sense of how you might be affected.
    A sense of history and understanding of detail are all well and good, but the bottom line is your bottom line.

    Here's the complication with the 2018 PFS: because of the wide variation in upward and downward adjustments, it's hard to make statements about how PTs in general will be affected. CMS estimates the overall impact at a 1%-2% reduction, but a lot depends on the types of patients a PT or clinic typically sees and what interventions are commonly used. Some providers could see increases.

    In an effort to clear up some of the uncertainty, APTA offers a calculator than can help you see how your typical case-mix would fare in the new PFS. The calculator, offered in Microsoft Excel, allows you to enter different codes to see what changes to expect, given your Medicare service area.

    4. Keep learning.
    There's much more to understand about the PFS—not just in terms of the details of how the new rule will work, but in terms of APTA's work to safeguard CPT codes throughout the misvalued codes review process.

    One great way to learn more about what to expect is coming up in December, when the association hosts a free webinar on Medicare changes for 2018 on December 6 from 1:00 pm to 2:00 pm ET. The webinar will be presented in a "flipped" format, meaning that when you register, you'll be provided with a prerecorded presentation to listen to in advance. That way, more of the actual session can be devoted to live interaction with the presenters. Be sure to sign up—and listen up—soon.

    Another opportunity is available December 13, when APTA hosts an "Insider Intel" phone-in session that will cover many of the same topics, albeit in a pared-down 30-minute session, from 2:00 pm to 2:30 pm ET. Instructions for signing up for this session are on APTA's Insider Intel webpage.

    The 2018 Physician Fee Schedule: Where We Are, How We Got Here, What's Ahead

    Here are a few things that can be said about the 2018 Medicare physician fee schedule (PFS) released by the US Centers for Medicare and Medicaid Services (CMS):

    1. It's a mixed bag in terms of adjustments to current procedural terminology (CPT) codes commonly used in physical therapy, with some values going up, and others being cut.
    2. Physical therapy isn't the only profession that saw CPT code reductions: otolaryngologists, nurse anesthetists, and urologists, to name a few, are also bracing for cuts.
    3. It could've been a lot worse—up to a 10% cut or more based on changes to the practice expense.
    4. Statements 1-3 aren't much consolation when you're a physical therapist (PT) facing estimated average payment reductions between 1.3% and 2% (but again, this is hard to pinpoint: there will be increases, but in other cases decreases will be even worse).

    What happened?
    Just a few months ago, the outlook was good for PTs when it came to next year's PFS. After a 2-year American Medical Association analysis of CPT codes that CMS believed may have been potentially "misvalued," the proposed rule that emerged was a clear win for the profession: no cuts to codes values, and even a few increases. From the perspective of the profession, the proposed rule adopted all of the positive recommendations from AMA—namely, no cuts and a few increases to work relative value units (RVUs)—and none of the damaging AMA recommendations, which included adjustments to practice expense (PE) inputs that would affect payment. Things were looking good, and APTA and its members advocated strongly for the rule as proposed.

    When the final rule was issued in November, things stopped looking so bright. Between release of the proposed rule and publication of the final version, CMS veered away from its typical process when it announced—without warning and without allowing opportunity for input from any stakeholders, including APTA—that it would reverse its decision and adopt the recommendations related to PE inputs. The rule change has altered the payment landscape for PTs in ways that are still being worked out by APTA. The association has published a summary of the rule on its website (listed under "APTA Summaries and Fact Sheets").

    Mapping the landscape
    While it's true that the final rule will result in increases in some areas, some of the payment reductions that will go into effect next year will hit home for some PTs. What is known for certain is that a few of the most commonly used codes in physical therapy will see a drop, including manual therapy, therapeutic exercise, mechanical traction therapy, and aquatic therapy.

    At the same time, other codes will increase—some significantly. Gait training therapy values will increase, as will neuromuscular reeducation, and therapeutic activities. Values for the 3-tiered evaluation codes adopted by CMS in 2016 also will rise (although the single value for all 3 tiers is maintained), in addition to orthotic management and training (first encounter), and prosthetic training (first encounter).

    APTA is putting final touches on a calculator that will help members get a more precise estimate of the potential impact of the new rule, given their particular practice circumstances. The calculator is set to be released early next week.

    "While it's clear that the CMS reversal from its proposed rule will result in drops to some of the codes used frequently by PTs, the bottom line effects of the new rule will vary depending on case mix and billing patterns," said Carmen Elliott, MS, APTA vice president of payment and practice management. "The overall 2% drop estimated by CMS doesn't take that variation into account. There will be some providers who will see reductions in payment of anywhere from 1% to 2%, but we anticipate that others could see overall increases."

    How we got here
    "This is frustrating, both in terms of the payment reductions as well as the way CMS surprised stakeholders with its reversal from the proposed rule. The cuts will be hard on some physical therapist practices," said APTA Vice President of Government Affairs Justin Elliott (no relation to Carmen Elliott). "It’s also true that the initial projections, long before the initial proposed rule, were far more bleak."

    Justin Elliott is referring to the way CMS handles codes that it believes may be "misvalued"—often read as a euphemism for "overpaid." It's a complex, multi-year process overseen by the AMA's Relative Value Scale Update Committee (known as RUC) Health Care Professions Advisory Committee (HCPAC). The RUC HCPAC engages in dialogue with stakeholder groups, including APTA, and conducts surveys of individual providers before issuing recommendations on how codes should be valued. The survey of PTs was conducted in October 2016.

    When the process began in early 2016, indications were that, overall, CPT codes commonly associated with physical therapy could see a double-digit cut. APTA staff and CPT advisors worked with the RUC HCPAC to move recommendations away from that potentially catastrophic change, and survey responses from PTs helped to reinforce the notion that current code values were not far off—at least in terms of averages across all codes.

    Given where things seemed to be headed in 2016, the release of the final rule, though far less than ideal, does amount to a win—of sorts. And context is important: physical therapy wasn't alone in professions with codes on the CMS chopping block, with otolaryngologists, anesthesiologists, nurse anesthetists, urologists, and vascular surgeons all seeing overall code reductions between 1% and 2%, according to CMS estimates.

    What's next?
    According to Justin Elliott, "APTA is exploring all avenues to advocate against these cuts before they take effect on January 1, 2018." He added, "All options are on the table and every path is being evaluated for our response to the final rule."

    Those advocacy efforts will require APTA and its members to have a solid understanding of just how the CPT changes impact them during the coming year, according to Carmen Elliott, who said that the key to getting insight on the effects is for PTs to continue to code and document appropriately while they evaluate their case mixes and other factors. "The only way to truly understand the effects of these changes is for our coding efforts to remain consistent," she said.

    At the same time, APTA President Sharon Dunn, PT, PhD, thinks there's an even bigger picture to be considered.

    "We can't yet say what the overall impact will be as a result of these code value changes, and we know that the effects will vary from provider to provider," Dunn said. "What we can say for sure is that these kinds of adjustments and recalculations truly underscore the need for health care providers to move toward value-based payment models that truly reflect the value of physical therapist services’ triple aim—improving the experience of care, improving population health, and reducing costs. The CPT code structure has 1 foot firmly planted in the outmoded fee-for-service world. That needs to change."