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  • CMS Sets Dec 1 Deadline for PQRS Appeals

    Did you participate in the Physician Quality Reporting System (PQRS) in 2016? You can check on your 2016 reporting results and find out if you're subject to any payment adjustments for 2018. But take note: if you’ve received a payment reduction notice and think the decision was made in error, you need to submit a request for review by December 1.

    The Centers for Medicare and Medicaid Services (CMS) released the reporting results—known as the Annual Quality and Resource Use Reports (QRURs)—as well as the feedback reports for online viewing on September 18. The 2016 PQRS feedback report contains all detailed information used to determine your 2016 reporting results and indicates if you are subject to the 2018 PQRS negative payment adjustment.

    More recently, CMS sent out individual notices to providers it believes did not meet PQRS requirements in 2016. Those providers are subject to Medicare Part B payment reductions beginning in 2018.

    If you have been identified for a 2018 payment reduction based on the report, and you think that decision was made in error, you'll need to ask for an informal review. CMS offers instructions on that process on the PQRS Analysis and Payment webpage. To make your appeal as effective as possible, be sure to thoroughly review your QRUR and provide detailed reasons why you think the reduction decision was a mistake—and don’t forget the December 1 deadline. APTA staff are available to answer emailed questions about the process at advocacy@apta.org.

    You can access the QRUR reports through the CMS "enterprise portal," but to do that you'll need an enterprise identity management (EIDM) account (CMS provides instructions for creating an EIDM). Also available: a user guide to the reports.

    For additional assistance regarding EIDM or the data contained in the PQRS feedback reports, contact the QualityNet Help Desk at 866/288-8912 (TTY 877/715- 6222) 7:00 am–7:00 pm CT, Monday through Friday, or by email at qnetsupport@hcqis.org. If you are having trouble accessing the PQRS feedback reports, contact the Physician Value Help Desk at pvhelpdesk@cms.hhs.gov or 888/734-6433.

    PQRS ended in 2016 and became part of the Merit-based Incentive Payment System (MIPS). For more information on the transition, check out PT in Motion magazine’s 2-part series on MIPS in the 2017 April and May issues.

    APTA Part of the Effort to Save Rural Hospitals

    Hospitals that serve rural areas are disappearing. APTA is supporting efforts to stop and even reverse that trend.

    "Medical deserts are appearing across rural America, leaving many of our nation's most vulnerable populations without timely access to care," according to the National Rural Health Association (NRHA), which estimates that between the 79 rural hospitals that have closed since 2010 and the additional 673 facilities that are on the brink of shutting their doors, the US is at risk of losing a third of its rural hospitals in the near future.

    The primary drivers behind the decline, according to NRHA, are federal cuts that began with the 2013 budget sequestration and so-called "bad debt cuts" imposed on facilities with certain levels of Medicare beneficiaries unable to make their cost-sharing payments. The organization is working to stop those and other damaging cuts, and APTA has joined in that effort. APTA is a member of NRHA.

    Like NRHA, APTA is advocating for passage of the Save Rural Hospitals Act (HR 2957). Introduced by Rep Same Graves (R-MO), the measure would stabilize rural hospitals by ending many of the Medicare cuts that are threatening the survival of the facilities. Additionally, the legislation introduces a new delivery model that would allow small rural hospitals and critical access hospitals (CAHs) to be recognized as community outpatient hospitals (COHs), a designation that would open up more possibilities for emergency and outpatient care in rural areas. To date, the legislation has 18 cosponsors in the House.

    APTA's support of the legislation is consistent with its positions on US Centers for Medicare and Medicaid (CMS) proposed rules for next year's outpatient and inpatient prospective payment systems. In the proposed outpatient rule—still not finalized—CMS says it will back off on enforcement of requirements for direct supervision of outpatient therapeutic services for critical access and small rural hospitals. The finalized inpatient payment rule includes language making medical record reviews a "low priority" when it comes to the requirement that physicians must certify that a patient admitted to a CAH will be discharged or transferred within 96 hours of admission. APTA supported both measures as much-needed changes that would help ease burdens on rural hospitals and CAHs.

    The association also is facilitating communication between physical therapists and physical therapist assistants who support rural hospitals and CAHs: recently, APTA launched a "rural health hub," an online community that allows members to share thoughts, questions, and strategies on working to keep rural care alive. Email advocacy@apta.org with your name and member number to gain access.

    "Rural hospitals are vital to the health and wellbeing of more than 62 million Americans," writes APTA President Sharon Dunn, PT, PhD, in APTA's letter of support for the Save Rural Hospitals Act. "Keeping these rural hospitals open is a necessity for so many Americans who need essential health care services."

    APTA will continue to advocate for passage of the legislation and is monitoring its progress. Updates will appear in PT in Motion News.

    New 'Rehab Therapists Give Back' Effort Helps Channel Donations to Hurricane Victims in Florida, Texas, and Puerto Rico

    Though the storms themselves have passed, people affected by Hurricane Harvey, Hurricane Irma, and Hurricane Maria will struggle with the devastation for the foreseeable future. Physical therapists (PTs), physical therapist assistants (PTAs), and other rehabilitation professionals now have an opportunity to come together as a unified community to help those in need.

    Earlier this month, electronic medical records system provider WebPT announced the launch of "Rehab Therapists Give Back," an online giving program with the goal of raising $1 million for people affected by recent hurricanes that destroyed parts of Houston, Texas, Florida, and Puerto Rico. Accessible through a GlobalGiving website, the initiative allows donors to contribute any amount to any of 4 relief funds.

    To help kickstart the campaign, WebPT made a $10,000 donation to the effort. APTA followed suit by committing a $10,000 donation match, which was met within 24 hours.

    "Many of our members have been asking about where they could make a relief donation," said Justin Moore, PT, DPT, APTA's chief executive officer. "The Rehab Therapists Give Back campaign is an ideal opportunity to join other professionals in showing our commitment to helping people rebuild their lives."

    Another future opportunity to give to a different cause through GlobalGiving: keep an eye on the new Health Volunteers Overseas (HVO) GlobalGiving website for future fundraising efforts that support education for the health care workforce in resource-scarce countries. APTA is a supporter of HVO, and several APTA members have participated in HVO efforts to support physical therapy in places such as Haiti, Rwanda, and Myanmar.

    Making the Profession's Voice Heard on Home Health: Multifaceted Advocacy Efforts Deliver Strong Message to CMS

    While the US Centers for Medicare and Medicaid Services (CMS) considers what to do with a proposed rule that APTA says creates "perverse financial incentives" for reductions in care in home health (HH), APTA and its members can be satisfied that the association, its components, and individual members mounted a strong, multifaceted education and advocacy effort that is likely to grab the agency's attention.

    The focus of the efforts is to stop CMS plans for a new HH payment system that reduces episodes of care from 60 to 30 days and shifts to a new case-mix model, called the Home Health Grouping Model (HHGM), that removes therapy service-use thresholds from the payment mix. CMS estimates that the combined effects of the proposed changes would result in a $950 million payment reduction to the HH payment system beginning in 2019.

    APTA identified glaring problems in the proposal almost immediately after it was released in late July and collaborated with the APTA Home Health Section to launch a series of advocacy efforts to ensure that CMS would receive a clear, unified, and strong reaction by the September 25 public comment deadline. Those efforts included:

    • A joint webinar with the APTA Home Health Section
    • Multiple meetings with policymakers on Capitol Hill, resulting in separate letters from Senator Orrin Hatch (R-UT) and 49 Senators, both telling the agency not to move forward with the HHGM proposal
    • Strategy discussions with other organizations, including the National Association for Home Care & Hospice and the Partnership for Quality Home Healthcare
    • Alerts to the PTeam, the association's advocacy network
    • Grassroots alerts to 4,300 members urging them to contact their member of Congress about stopping the HHGM plan
    • Meetings with CMS representatives in which APTA was joined by representatives from the American Occupational Therapy Association and the American Speech-Language-Hearing Association to discuss shared concerns
    • Educational sessions on the HHGM at the APTA State Policy and Payment Forum held in mid-September
    • A podcast created with Talus Media
    • The creation of a template letter for members to use in writing to CMS about the proposed rule

    A final decision on the proposed rule isn't likely to be released until sometime in November, but CMS records show that APTA's grassroots advocacy efforts made an impact, at least when it comes to the contents of the CMS inbox: as of the comment deadline, CMS reports that it has received 1,349 comments on the HH rule.

    "At this stage we don't know where CMS is going with the HHGM," said Kara Gainer, APTA's director of regulatory affairs. "But the level of collaboration and individual effort throughout the association, combined with our cooperative efforts with other organizations opposed to the rule, has sent a very clear and forceful message to CMS. We think this proposal will harm patients, and we hope CMS is getting that message loud and clear."

    CMS Shelves Controversial Orthotics and Prosthetics Proposal

    The US Centers for Medicare and Medicaid Services (CMS) has killed a controversial proposal that would have restricted many physical therapists (PTs) from furnishing custom orthotics and prosthetics. The proposal was opposed by APTA and a host of other provider and patient advocacy organizations.

    The proposed rule, issued in January, would have required PTs to be "licensed by the state [as a qualified provider of prosthetics and custom orthotics], or…certified by the American Board for Certification in Orthotics and Prosthetics…or by the Board for Orthotist/Prosthetist Certification." The association voiced its opposition to the CMS plan, characterizing the proposal as a set of unnecessary requirements that would limit patient access to appropriate care.

    The March 13 deadline for comments passed, and CMS issued no further communication on the proposal until last month, when a notice that the proposal was being withdrawn from the White House Office of Management and Budget’s “Unified Agenda” indicated that the proposal was no longer under active consideration by CMS. On October 3, notice that the proposal would be officially withdrawn appeared in the Federal Register, with the withdrawal document itself scheduled to be published the next day.

    The withdrawal represents a win for thousands of PTs who would have been saddled with significant additional regulatory and financial burdens in order to qualify as a provider. In addition to its direct comments to CMS, APTA's advocacy efforts included meetings with CMS and the creation of a template letter to be used by many members to voice their individual opposition to the proposal.

    Problems With Humana Claims? Let APTA Know

    Physical therapists (PTs) in several states are reporting claims difficulties with Humana's commercial and Medicare Advantage insurance plans, but more input from providers is needed.

    Recently, PTs from several states including Florida, Ohio, Kentucky, Louisiana, Virginia, and West Virginia have contacted APTA about Humana-related payment issues that include the retroactive application of the multiple procedure payment reduction (MPPR), further reductions to in-network providers' rates through the MPPR, confusion around Humana's approach to anatomical modifiers, and inconsistent application of the 59 modifier, with denials occurring even when the modifier was visible on the claim.

    In addition, the association has received reports of providers having difficulty accessing Humana personnel to discuss claims issues, and a lack of notification when policies and processes change.

    APTA staff have been in discussion with a representative from Humana to facilitate a resolution to the problems. As part of those efforts, APTA is urging members to contact the association by email at advocacy@apta.org, or by phone at 800/999-2782, extension 8511, to share any new or ongoing issues they've had with Humana.

    Need more information on retroactive claims denials and adjustments? Check out this APTA webpage. Also available: resources from Humana on postpayment recoupment, claims coding processing edits, and gaining a better understanding of other Humana processes.

    APTA: CMS Proposal for Home Health Creates 'Perverse Financial Incentives' to Reduce Care

    APTA delivered comments to the US Centers for Medicare and Medicaid Services (CMS) that make no bones about the agency's proposed changes to the home health payment system. The bottom line, according to the association: The plan contains "significant flaws" that "will have a harsh and dramatic effect on patient care." And what's more, APTA says, CMS may not have the legal authority to do what it wants to do, at least in the way it hopes to do it.

    The letter from APTA provides a detailed deconstruction of a CMS proposal to radically change the payment environment for home health (HH) in ways that would directly impact patients, physical therapists (PTs), and physical therapist assistants (PTAs)—and not for the better. Those proposed changes would move episodes of care from 60 to 30 days, and would include the adoption of a new case-mix model, known as the Home Health Grouping Model (HHGM), that removes physical therapy service-use thresholds from the mix.

    All told, the changes being proposed could result in a $950 million payment reduction to home health, according to CMS. And CMS wants to roll out the new system in 2019. The CMS proposal generated a strong reaction in the HH community in general, and within APTA in particular, resulting in a record-breaking number of individual comment letters submitted to CMS, facilitated by template text that APTA made available online.

    In its letter to CMS, APTA provides comments on the entire package of proposals, but focuses particular attention on the HHGM, which it describes as a system that "undervalues the important role of rehabilitation and creates perverse financial incentives to deliver less than appropriate care." APTA's letter acknowledges the importance of creating health care delivery systems that are "better, smarter, and healthier," but argues that the HHGM moves things in the opposite direction.

    APTA writes that as a whole, the HHGM "lacks person-centeredness and…fails to support proven interventions to address behavioral, social, and environmental determinants of health. While CMS has committed to putting first the best interest of the people it serves, the motivation behind the HHGM appears to focus solely on reducing Medicare spending."

    On top of that, says APTA, CMS may be going about its proposal in a way that exceeds its authority. The association's argument is based on statutory limitations that require CMS to implement changes in a "budget neutral" manner, meaning that only Congress has the authority to impose changes that significantly impact the HH budget, down or up. APTA writes that while CMS was provided with a temporary window to make non-budget-neutral adjustments under the Affordable Care Act (ACA), that window closed this year.

    "Unless the statute says otherwise, changes to elements of [home health payment systems] must be made in a budget-neutral manner across the system," APTA writes. "If the HHGM unintentionally causes access problems through rate cuts instituted by regulation, Congress would then be tasked with finding budget offsets to cover the 'cost' of fixing the mistake."

    Making matters even worse, according to APTA, is the CMS proposal to begin implementing the HHGM in 2019. The association asserts that if it moves forward, the new model shouldn't be rolled out any earlier than 2020, and that more dialogue and education take place before a finalized system is put in place.

    Among other elements of APTA's comments:

    • APTA encourages CMS not to eliminate rural add-on payments in 2018, citing concerns that the change would worsen workforce shortages in rural areas.
    • The association supports proposed modifications to the HH Quality Reporting Program and Value-Based Purchasing Program, and is in favor of "overarching" CMS strategies around assessing and adjusting for social risk factors.
    • APTA urges CMS to move away from its proposal to use a single diagnosis to categorize an episode into a clinical grouping, and instead allow for combinations of diagnoses to ensure proper therapy interventions. Similarly, the association recommends that CMS expand its list of comorbidity subcategories "to better capture diagnoses that cause higher resource allocation."

    Still, the association's most significant concerns are linked directly to the HHGM.

    "The HHGM would not improve patient care or aid CMS in aligning home health [prospective payment systems] with its overarching…policy goals," APTA writes. "We believe the HHGM would create new program integrity issues, compliance challenges for providers, and new access issues for beneficiaries."

    US Senate Makes Statement With Language to Bring PTAs Into TRICARE

    APTA's efforts for revision of the TRICARE payment system to include services by physical therapist assistants (PTAs) got a big push on September 18 when the Senate passed its version of the National Defense Authorization Act (NDAA). TRICARE is a major part of the US Department of Defense health care system.

    The Senate bill includes an amendment to NDAA that calls for the US Secretary of Defense to revise TRICARE so that it recognizes PTAs (as well as occupational therapy assistants). APTA worked with the office of Sen Thom Tillis (R-NC) to introduce the amendment.

    The Senate victory comes on the heels of report language included in the House of Representative’s version of the NDAA that calls for a review on the feasibility of adding PTAs and designated others as health care providers in the military health system, to be completed by April 1, 2018.

    "APTA has long supported PTAs being included in TRICARE, and we're encouraged by this progress," APTA President Sharon L. Dunn, PT, PhD, said about the Senate bill. "Including PTAs in TRICARE will make it easier for uniformed service members and their families to get the quality care they need and deserve." Dunn is a board-certified clinical specialist in orthopaedic physical therapy.

    Representatives from the Senate and House armed services committees now are expected to come together in a conference and work out the differences in the 2 bills. No schedule is set for the conference yet, but with language in both versions APTA believes chances are good that PTA recognition will be included in the final bill that eventually is signed into law. It’s too early to project how long after that implementation would occur, but the association notes that the Senate version is more directive and would take less time to implement than the House bill.

    APTA will continue to educate the chairs of the Senate and House committees to help ensure the best possible language in the final law. Association members with questions can contact Michael Hurlbut, APTA senior congressional affairs specialist, at michaelhurlbut@apta.org.

    PT, PTA Students Use 'Flash Action' Against the Therapy Cap

    A physical therapist (PT) and physical therapist assistant (PTA) student-led "flash action strategy" (FAS) held last week was all about stopping the Medicare therapy cap.

    And once again, students showed how enthusiasm for the profession can make a real difference.

    In the middle of packed semesters, students from dozens of schools across the country participated in a nationwide effort to press for repeal of the therapy cap. Primarily using social media, participants concentrated their efforts during a 48-hour window of intense messaging, September 12-13. Between an early alert on September 11 and some final action the morning of September 14, more than 10,000 emails, letters, faxes, and phone calls went out to members of Congress via APTA's Legislative Action Center and Patient Action Center. The latter, where consumers can contact their members of Congress, saw a nice uptick in registrations during the FAS, largely thanks to APTA members encouraging nonmember colleagues, family, friends, and patients to participate.

    Even though the FAS is over, APTA still needs members' efforts toward repeal of the therapy cap by year-end. That's when the latest extension of the exceptions processes expires, and the hard cap on Medicare payment for outpatient physical therapy services will be implemented. The Medicare Therapy Cap webpage explains how to email and meet with legislators, download the APTA Action app, and join the APTA PTeam to receive updates and alerts.

    PT and PTA students will bring their energy and excitement to the upcoming APTA National Student Conclave , set for October 19-21 in Portland, Oregon.

    Funding Opportunity for Chapters, Practices to Encourage Activity for People With Arthritis

    APTA chapters and individual physical therapy practices have a new incentive to start or enhance programs that encourage people with arthritis to be more active—but time is short to take advantage of it. APTA is collaborating with the National Association of Chronic Disease Directors (NACDD) and the Centers for Disease Control and Prevention (CDC) in a program that will award 6 grants of about $4,100 each to selected applicants. The grants specifically are for activities to increase consumer access to the Arthritis Foundation’s Walk With Ease (WWE) self-directed program.

    Applicants must propose how they will use the funds to implement the WWE self-directed program, either alone or in collaboration with community partners or state arthritis programs. Funds can be used to purchase participant WWE guidebooks and marketing materials, and to cover administrative costs. Grant recipients are expected to enroll 400 participants during the 9-month project period, which begins in November 2017.

    Applications are due Friday, September 29, 2017, at 11:59 pm EST. More information, including program requirements, application instructions, and links to download the application (in Word and fillable PDF formats), is available on the NACDD website.

    APTA’s Arthritis Management Through Community-Based Programs  webpage includes a link to the Walk With Ease program along with a wealth of other resources.