Did you know that Medicare payments will be increased by 0.5% effective July 1? Stay on top of the new rates with APTA's MPPR calculator—an outpatient therapy claim pricer that can help you determine your payment for services.
Tip: Be sure to click on the calculator that corresponds to the date service was provided.
Spring is gone, summer's here, and the US Centers for Medicare and Medicaid (CMS) just keeps on churning out more proposed and final rules that can have a big impact on physical therapists (PTs) and physical therapist assistants (PTAs). Sometimes the changes will be felt directly by PTs and PTAs; sometimes the changes affect how employers will operate; sometimes the changes have to do with the ways beneficiaries interact with the systems.
The regulatory affairs staff at APTA keeps a close eye on all of the rulemaking and creates detailed resources that can keep you up to speed. It's all part of an effort to untangle rules that can seem dizzingly complex—but should not be ignored.
Here are 5 rules you should know about—4 proposed and 1 final—and what APTA offers for a more detailed take.
Acute care hospitals and long-term care hospitals (proposed rule)
The IMPACT Act signed into law last year is sparking some significant changes around the kind of data long-term care facilities gather and report, with emphasis on standardized quality reporting across the different types of postacute care facilities—long-term care hospitals, inpatient rehabilitation facilities, skilled nursing facilities, and home health agencies. CMS estimates that Medicare spending on inpatient hospital services will increase by about $120 million in FY 2016.Available from APTA: summary and highlights, comments to CMS
Skilled nursing facility (SNF) prospective payment system (proposed rule)
CMS is proposing an increase in payments to SNFs, and also implementing a SNF quality reporting program by 2018. Again, the IMPACT Act plays a big role in the proposal, with requirements for new quality measures for the SNF quality reporting program. Also worth noting—new rules on mandatory reporting about staffing, including hours worked and employee turnover.Available from APTA: summary and highlights, comments to CMS
Inpatient rehabilitation facility (IRF) prospective payment system (proposed rule)
IRFs will receive an average overall estimated increase of 1.7% in 2016. Like other postacute care settings, IRFs would be subject to increased quality reporting requirements for quality domains identified in the IMPACT Act. CMS also proposes 4 additional functional status measures for IRFs.Available from APTA: summary and highlights, comments to CMS
Medicaid Managed Care Organizations (proposed rule)
The first major change proposed to Medicaid in a dozen years, the rule is described by Health Affairs as "a defining moment" for the program. The rule takes aim at how Medicaid managed care plans can market to consumers, and how the plans can be integrated with the health care exchanges developed through the Patient Protection and Affordable Care Act (ACA). The proposal, which also affects the Children's Health Insurance Plan (CHiP), would increase program integrity and quality improvement requirements.Available from APTA: summary and highlights (comments under development)
Medicare Accountable Care Organizations (ACO) (final rule)
The final CMS rule on Medicare ACOs includes more flexibility for the care networks, which now number nearly 400 and serve an estimated 7 million beneficiaries. Among other changes, the rule opens up a "third option" for ACOs that involves taking on more risk in exchange for the potential to keep more money linked to savings. The new rule also opens up the possibility for ACOs to avoid penalties beyond the 3-year timeframe previously established by CMS,Available from APTA: summary and highlights of final rule
Plus: Stay tuned for one of the year's most-anticipated rules—the CMS proposal for next year's physician fee schedule, likely to be released on or around July 1. Also due to drop soon: proposed rules on home health and outpatient hospitals. APTA will review all proposed rules and create a highlights resource, as well provide comments to CMS.
A bill that would help some physical therapists (PTs) in private practice improve continuity of care has been approved by the US Senate Finance Committee, and could be up for a vote on the Senate floor soon. Known as the Prevent Interruptions in Physical Therapy Act (S. 313), the legislation would extend so-called "locum tenens" provisions to PTs in rural and underserved areas—a change strongly supported by APTA and its Private Practice Section, and one of the advocacy areas targeted at the recent PT Day on Capitol Hill and at the joint APTA/Private Practice Section (PPS) legislative fly-in earlier this year.
The bill now being discussed would allow a PT to bring in another licensed physical therapist to treat Medicare patients and bill Medicare through the practice provider number during temporary absences for illness, pregnancy, vacation, or continuing medical education. To limit budgetary impact, the legislation was amended to allow locum tenens for PTs only in non-Metropolitan Statistical Areas, Medically Underserved Areas (MUAs), and Health Professions Shortage Areas (HPSAs) as defined by the US Department of Health and Human Services.
A companion bill has been introduced in the US House of Representatives (H.R. 556). If the bill is approved by Congress and signed into law, private practice PTs in these designated areas would join doctors of medicine, osteopathy, dental surgery, podiatric medicine, optometry, and chiropractic on the list of locum tenens providers.
The bill was introduced by Sens Charles Grassley (R-IA) and Bob Casey (D-PA) in the Senate; Reps Gus Biliraikis (R-FL) and Ben Ray Lujan (D-NM) are leading the House efforts. APTA and PPS collaborated on pressing for the legislation, which APTA identified as a goal of its public policy priorities.
During the Senate Finance Committee hearing on the bill, Grassley stated that "physical therapists provide important and necessary services to their patients, and should have the ability to ensure continuous care for their patients when a period of short-term leave is needed." Casey added that he and other supporters of locum tenens for PTs "want to keep working until these arrangements are allowed nationwide."
Sen Charles Grassley (R-IA)
speaks in favor of locum tenens for PTs.
"This is a much-needed correction that will have a significant impact on the care some PTs can provide their patients and clients," said Terence Brown, PT, PPS president. "We're extremely pleased with the strong possibility that small or solo physical therapy practices in rural and underserved areas will soon be able to avoid interruptions in care that can truly impact patient progress."
APTA President Sharon Dunn, PT, PhD, OCS, called the news of the bill's advance a "definite win for physical therapy," saying the success so far is due in large part to the combined efforts of APTA, PPS, and individual members who contacted their legislators—and even showed up in lawmakers' offices in-person during PT Day on Capitol Hill, held June 4.
"The push for locum tenens is part of larger efforts by APTA and its members to truly transform patient access to care," Dunn said. "We are hopeful for passage of this legislation and, with it, the reduction of an unnecessary regulatory barrier. It's part of a bigger picture that our members see clearly, and we're taking that vision to lawmakers."
APTA will monitor the progress of the bills and post updates to its locum tenens webpage. Resources on the website include a podcast on the importance of this legislation and information on how PTs can get involved in advocating for its passage.
The following members were elected to APTA's Board of Directors and Nominating Committee on Monday at the House of Delegates in National Harbor, Maryland.
Sharon L. Dunn, PT, PhD, OCS, was elected president.
Lisa K. Saladin, PT, PhD, FASAHP, was elected vice president.
Jeanine M. Gunn, PT, DPT, was reelected director, and Susan A. Appling, PT, DPT, PhD, OCS, and Robert H. Rowe, PT, DPT, DMT, MHS, FAAOMPT, were elected director.
Scott Euype, PT, DPT, MHS, OCS, was elected to the Nominating Committee.
These terms become effective at the close of the House of Delegates on Wednesday.
Legislation that would include physical therapists (PTs) among the professions included in a federal program to provide greater patient access to health care in underserved areas was introduced in both the US House of Representatives and Senate, just in time to be included in the grassroots advocacy efforts taking place during PT Day on Capitol Hill June 3-4.
The Physical Therapist Workforce and Patient Access Act (H.R. 2342/S. 1426) was reintroduced late last week and, if passed, would allow PTs to participate in the National Health Service Corps (NHSC) loan repayment program, an initiative that repays up to $50,000 in outstanding student loans to certain health care professionals who agree to work for at least 2 years in a designated Health Professional Shortage Area (HPSA).
The bill was introduced in the House by John Shimkus (R-IL) and Diana DeGette (D-CO), and in the US Senate by John Tester (D-MT) and Roger Wicker (R-MS). The timing of the reintroduction couldn't be better, as an estimated 1,000 PTs, physical therapist assistants (PTAs), and students from PT and PTA programs descend on Washington, DC, to join in PT Day on Capitol Hill on June 4. Events will begin with a rally before participants fan out across the halls of Congress to advocate for increased patient access to PTs, loan forgiveness, the Medicare therapy cap, and other issues.
APTA is a strong supporter of legislation that extends student loan forgiveness to PTs, particularly as a way to improve access to physical therapist services in areas already experiencing shortages.
"Based on current trends in the physical therapist workforce, the shortage of physical therapists could potentially reach over 27,000 in the United States by 2020, greater than other primary care disciplines recognized by the [NHSC]," APTA notes in a position paper on the legislation (.pdf). "The inclusion of physical therapists in the NHSC Loan Repayment Program will help to ensure that rehabilitation services are available to underserved communities."
Find out more about PT workforce legislation—including details about the NHSC loan repayment program and what you can do to advocate for the profession—at APTA's Education and Workforce Legislation webpage.
Work in a postacute care setting? Brace yourself for IMPACT.
New to the APTA website: a webpage exclusively devoted to providing you with everything you need to know about postacute care reform in Medicare, including information on how the Improving Post-Acute Care Transformation (IMPACT) Act will change the types and quantity of data provided to the Centers for Medicare and Medicaid Services (CMS).
The new webpage provides a basic outline of the principles behind postacute care reforms, resources from CMS, summaries of proposed rules, and highlights of APTA's involvement in the process.
The reach of IMPACT and other postacute care reforms extends to skilled nursing facilities, home health, inpatient rehabilitation facilities, and long-term care hospitals. APTA is a strong supporter of the reform initiatives, including the provisions of the IMPACT Act.
With no further delays on the horizon, the shift to the new International Classification of Diseases, 10th Revision (ICD-10) is set for October 1. Physical therapists (PTs) have one more chance to capitalize on an opportunity to test the new system before actual implementation, but only if they act quickly.
The last of 3 ICD-10 test programs that the Centers for Medicare and Medicaid Services (CMS) has conducted for health care providers is scheduled for July 20-24, and the deadline to apply is May 22. APTA is encouraging members to sign up for the program to gauge their own practice's readiness for the change.
Bonus for any PTs who already participated in the January or April end-to-end tests: you can participate again in July without reapplying.
The testing program will allow a sample group of providers to work with Medicare administrative contractors (MACs) and Common Electronic Data Interchange (CEDI) contractors to evaluate the system for processing the new codes, from submission to remittance advice. That testing process will include submission of claims with ICD-10 codes to the fee-for-service claims system, adjudication of claims, and the production of accurate remittance advices.
CMS is targeting a broad cross-section of providers and will select testing participants based on needs for the study. Volunteers can apply through their MAC's website but must do so by May 22. The MACs and CEDI will notify the volunteers selected by June 12 with information needed for the testing.
More information on the testing process is available online (.pdf).
Need more information on what the change to ICD-10 means for your practice? Visit the APTA ICD-10 webpage, which includes background and resources.
If you think the new Medicare legislation is only about ending the sustainable growth rate (SGR) and extending therapy cap exceptions for 2 years, think again: the new authorization act also contains some substantial changes around manual medical review, quality reporting, and incentives for participation in alternative payment models, to name a few.
Highlights of the changes (.pdf) taking place through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) are now available on the APTA website. Some of the changes were imposed immediately; others will be implemented over time. The bottom line: MACRA is laying the groundwork for a significant transformation in how physical therapists (PTs) and other health professionals are paid.
Among the changes:
Manual medical reviews of therapy cap exceptions won't be based solely on dollar amounts.
Sometime around mid-July, the $3,700 trigger for manual medical review (MMR) will be replaced with a system that links MMR to provider behavior and other factors. CMS will look at whether a provider has a pattern of "aberrant" billing practices, the provider's claims denial percentage, whether the provider is newly enrolled, what types of medical conditions are being treated, and whether the provider is part of a group that includes another provider who has been identified in terms of the those factors. The new process will apply to exception reviews that have not been conducted by the anticipated July startup date. APTA will meet with CMS to discuss implementation, and will share details with members over the coming months.
PQRS, value-based modifiers, and electronic health records meaningful use may be consolidated into a single new quality program.
These quality programs stay in place for now, but prepare for MIPS—the Merit-Based Incentive Payment System—set to be launched in the future. MIPS will evaluate performance according to quality, resource use, meaningful use, and clinical practice improvement. There are still many details that need to be worked out in terms of the reach of these programs in the future.
Participation in alternative payment models (APMs) could be a rewarding experience.
CMS will offer 5% bonuses to PTs and other health care professionals involved in APMs such as accountable care organizations, medical homes, and bundled care systems. Beginning in 2026, CMS will stratify annual updates, providing a .75% annual update to health care professionals engaged in APMs, and .25% for those who aren't.
Other changes in the new law include a new 1% payment update factor for postacute care providers; the inclusion of physician assistants, nurse practitioners, and nurse clinical specialists as professionals qualified to provide documentation for certain types of durable medical equipment; and requirements that Medicare administrative contractors (MACs) provide ongoing outreach, education, training, and technical assistance to providers.
Want more information on how the therapy cap exceptions process will work under MACRA? Check out the newly revised therapy cap FAQs.
Significant improvements to research on rehabilitation—a longstanding policy priority for APTA, and an important element in accomplishing the association's transformative vision—are at the center of proposed bipartisan legislation on Capitol Hill that aims to foster and better coordinate this type of research at the National Institutes of Health (NIH).
Titled the Enhancing the Stature and Visibility of Medical Rehabilitation Research at the NIH Act (S. 800; H.R. 1469), the companion bills were introduced in the Senate by Sens Mark Kirk (R-IL) and Michael Bennett (D-CO), and in the House by Reps Jim Langevin (D-RI) and Gregg Harper (R-MS) on March 19. The legislation would reform practices at NIH around how rehabilitation research is integrated across the Institute's research centers, and how often research plans are reviewed and updated.
Among the proposals in the legislation:
The proposed changes build on recommendations from an NIH blue ribbon panel that was co-chaired by Rebecca Craik, PT, PhD, with members that included Anthony Delitto, PT, PhD, and Alan M. Jette, PT, PhD. The panel's recommendations, issued in 2013, were supported by APTA, with APTA President Paul A. Rockar Jr, PT, DPT, MS, characterizing the findings as ones that reflect APTA's "core principles," and are "critical to meeting the NIH's mission and impacting society in a positive manner."
Improvements to rehabilitation research and support of NIH work in this area are among APTA's public policy priorities. In addition to its individual advocacy efforts, the association is a member of the Disability and Rehabilitation Research Coalition, a group of more than 40 organizations working together to promote this type of research.
"Along with our fellow members in the coalition, we are extremely happy about the introduction of these bills," said Justin Moore, PT, DPT, APTA executive vice president of public affairs. "We fully supported the NIH blue ribbon panel's recommendations, which are clearly reflected in this legislation. If passed into law, these changes would represent a real move forward for rehabilitation research and its ability to transform lives."
APTA will continue to monitor and report on the progress of these bills.
The US Senate voted Tuesday to approve a bill that repeals the flawed sustainable growth rate (SGR) and moves toward payment systems based on quality, but, despite a concerted, historic grassroots advocacy effort, does not end the Medicare outpatient therapy cap. The therapy cap repeal amendment was defeated by a 58-42 vote, coming up just short of the 60 votes needed for passage.
Instead of a full repeal, the therapy cap exceptions process will extend until December 31, 2017.
The vote on the SGR ends a flawed system for payment that would have resulted in 21% reductions in Medicare payments to providers. The bill approved by the Senate passed with an overwhelming 92-8 vote, and President Barack Obama has stated that he will sign it into law. The bill was approved by the House in late March.
Among the most significant features of the bill are the ways it sets the stage for a transition to value-based health care services, and away from the fee-for-service model—a shift strongly supported by APTA.
The effort to include an amendment to end the therapy cap was championed by Sen Ben Cardin (D-MD) along with Sen David Vitter (R-LA), and was the focus of an intensive effort by APTA, its members, supporters, and other organizations to urge senators to vote in favor. In the end, the amendment was 1 of only 6 allowed to be considered, and among those 6, garnered 1 of the highest number of votes in favor.
"Ending the SGR is good news not just because it ends a flawed policy, but because it's helping to transform payment models," said Justin Moore, PT, DPT, APTA executive vice president of public affairs. "We are of course disappointed that the therapy cap repeal effort was not successful, but thanks to the hard work of APTA members and supporters, we were able to seize an historic moment and move this issue closer to the goal line than at any time in the 18-year history of the cap. We will capitalize on this energy, unity, and momentum, and will never stop working for the best interests of patients."
APTA will provide further information and resources on the provisions passed in the SGR bill over the coming weeks and will continue to influence its implementation with the Centers for Medicare and Medicaid Services.
American Physical Therapy Association | 1111 North Fairfax Street, Alexandria, VA 22314-1488 703/684-APTA (2782) | 800/999-2782 | 703/683-6748 (TDD) | 703/684-7343 (fax)
Contact Us | For Advertisers & Exhibitors | For Media | Follow APTA
All contents © 2014 American Physical Therapy Association. All Rights Reserved.