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May 24, 2016
To say that initiatives toward reforming payment and delivery systems for health care services are moving rapidly in 2016 would be an understatement. Even though efforts by numerous stakeholders—among them Congress, the Department of Health and Human Services, private payers, health care systems, and professional societies such as APTA—have been under development and implementation since the Affordable Care Act in 2010, the execution and launch of many initiatives is becoming real and tangible in 2016. It is clear from current initiatives and potential activities that the shift to value-based payment for health care services is happening now.
As we approach the halfway mark into 2016, it seems appropriate to provide a mid-year update on some of the varied efforts that, combined, are shaping the future of health care payment and practice. These include the review of potentially misvalued Current Procedural Terminology (CPT) codes identified by the Centers for Medicare and Medicaid Services (CMS) and the American Medical Association (AMA) now under way; the new physical therapy evaluation and reevaluation CPT codes scheduled to begin in 2017, as well as the intervention codes under consideration; the proposed 2017 MACRA rule announced earlier this month; and the CJR model that began April 1.
In the 2016 Medicare physician fee schedule rule (MPFS), CMS finalized a list of 103 CPT codes that it believes are misvalued. This is not a new process; CMS is mandated to review relative values for codes for all services paid for under the MPFS at least every 5 years. The identified codes are used by various health care providers, and among them are 10 physical medicine and rehabilitation (PM&R) codes that now must go through a value review process by AMA and CMS. In making recommendations to AMA for the review, our charge at APTA is to best position the codes for their future use. This strategy includes potentially updating code descriptor language and surveying codes within the 97000 series, which could happen as early as this summer, to prepare the PM&R code set for the changes we are experiencing in health care.
Also within the PM&R code set is the highly anticipated 2017 physician fee schedule, which will include information about the new CPT physical therapy evaluation and reevaluation codes. Because the proposed codes are proprietary to AMA, which owns and publishes the CPT codes, APTA is prohibited from sharing any information about them until CMS releases them within the proposed fee schedule this summer. But the association is developing educational resources for individual members and its components to prepare clinicians for implementation January 1, 2017, and will make them available in early September. In addition to the evaluation codes, APTA also has been involved in an AMA work group to revise and reform the intervention codes—those used to describe the treatment or intervention component of the physical therapy plan of care developed from the evaluation. This effort is currently suspended due to the review of the misvalued codes, and because of concerns that the initially proposed intervention codes would need further development prior to implementation.
As APTA reported earlier in May, CMS announced the proposed rule for the Medicare and CHIP Reauthorization Act (MACRA), which implements a new quality program and the opportunity to participate in new payment models. While PTs will not be subject to the quality requirements in the proposed rule in 2017, it will be to the advantage of individual PTs and to our profession to get up to speed on these provisions, as they represent tangible and significant steps toward payment based on quality of care and outcomes. You can read APTA's top 5 takeaways from the proposed rule for more insight.
Moving to the Comprehensive Care for Joint Replacement Model (CJR), the program has been in place since April 1. APTA's resources are periodically updated to address questions and issues being identified as PTs within the affected metropolitan areas find their place within the program. An upcoming webinar this fall will review how things are going and lessons we’ve learned since the launch of the Medicare model. Look for information on the webinar, and for other valuable APTA resources on CJR, on the dedicated webpage at www.apta.org/CJR.
There is no question that the health care payment and practice environment already looks different in this first half of 2016, and we can expect even more change by the time we reach January 1, 2017, just 6 short months away. APTA will continue to provide you with the resources and information you need to stay current, as this represents the future of health care payment and delivery. Physical therapy will be critical to reforming our health care system to achieve the triple aim—lowering costs, improving the health of individuals, and providing better-quality health care to all. We appreciate our members in leading the profession forward in this new era of payment in physical therapy.
Sharon Dunn, PT, PhD, OCS
President, American Physical Therapy Association