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  • The 2019 Fee Schedule, Part 3: The End of FLR, the Move to PTA-Specific Codes, and a Nod to Technology

    Part 3 of a 3-part series on the proposed 2019 Medicare physician fee schedule. This installment: there's more to the proposed rule than PTs being required to participate in the Quality Payment Program—including some very good news.

    The fact that physical therapists (PTs) could be widely engaged in a value-based payment model in 2019 is definitely the big takeaway from the proposed 2019 physician fee schedule released by the US Centers for Medicare and Medicaid Services. But the sweeping proposal also includes some other significant changes that could affect both PTs and physical therapist assistants (PTAs). Here's a rundown of 3 of the biggest non-Quality Payment Program-related changes included in the proposed rule.

    Something to celebrate: the end of functional limitation reporting (FLR).
    Criticized by APTA as an undue administrative burden that yields little of value, FLR would finally be put out to pasture if the proposed rule is adopted. In its reasons for eliminating the requirement, CMS described the "general consensus" of commenters responding to a CMS request for ways to reduce administrative burden that FLR was "overly complex and burdensome." The agency estimates that PTs in private practice would have saved between 130,000 and 190,000 hours of administrative work in 2017 had FLR not been in place.

    The change is a win for APTA and its members, and the association is mentioned in the proposed rule as a "specialty society" that supplied CMS with data on the inconsistent timing of FLR reporting—another issue that fueled the decision to eliminate the requirement.

    Something to be concerned about: is CMS setting the stage for the PTA payment differential?
    If enacted as proposed, the rule would establish 2 new therapy modifiers to identify the services furnished in whole or in part by PTAs or occupational therapy assistants (OTAs) beginning. January 1, 2020. The modifiers, mandated by the Bipartisan Budget Act of 2018, would be used in place of the GP and GO modifiers—the ones currently used to identify PT and OT services furnished under an outpatient plan of care—and will pave the way for a planned payment differential that would reimburse services provided by PTAs and OTAs at 85% of the fee schedule beginning in 2022.

    Although the modifiers won't officially be in place until 2020, CMS plans on accepting voluntary use of the modifiers next year. CMS also proposes to define “in part” to mean any minute of the outpatient therapy service that is therapeutic in nature and that is provided by the PTA or OTA when acting as an extension of the therapist. The new modifiers would not be applied when a PTA or OTA furnishes non-therapeutic services—such as scheduling appointments, greeting the patient, or preparing the treatment area.

    APTA is opposed to the adoption of a payment differential system and will be advocating for changes before the 2022 implementation date.

    Something to keep an eye on: CMS may be warming up to broader use of technology.
    While it appears that, for now at least, the changes will be limited to physicians and other qualified health professionals who can report evaluation and monitoring services, CMS is proposing that activities such as virtual check-ins, interprofessional internet consultation, and remote evaluation of prerecorded patient information could qualify for some form of payment. APTA is seeking clarification from CMS as to whether any of these services could be furnished and billed by PTs.

    Get ready for the future of PT payment: APTA offers a wide range of online resources on value-based care, including a readiness self-assessment quiz, a podcast series, a video, and more. Additionally, APTA's Physical Therapy Outcomes Registry has earned "qualified clinical data registry" status from CMS, meaning that PTs who participate in MIPS can use the Registry to submit their data to CMS.

    Comments

    • Hello, I am reaching out to see if you can provide me a link on how to keep updates on what is being talked about specifically for the PTAs with this new bill and the 85% reimbursement rates. Also, if I can be provided with who is representing/advocating for us(PTAs) during this process. I have looked on numerous web pages including APTA but find minimal information on how APTA is opposing this motion. And minimal information for PTAs in general? Any help would be greatly appreciated. -Nickol Madrid, SPTA

      Posted by nickol madrid on 12/18/2018 4:07 PM

    • Nockol - thanks for the question! Information on the PTA modifier and payment differential policy can be found here: http://www.apta.org/Payment/Medicare/2019/Changes/. Additionally, the 2019 Medicare physician fee schedule final rule fact sheet provides an overview of what CMS finalized in this year’s rulemaking in regards to the PTA modifier: http://www.apta.org/Payment/Medicare/CodingBilling/FeeSchedule/FactSheet/2018/11/29/ As we have updates to share regarding the policy, we will post them to one or both of the following webpages, as well as alert members via social media and/or PT in Motion News. • Payment for therapy services: http://www.apta.org/Payment/Medicare/CodingBilling/TherapyCap/?navID=10737430585 • Physician fee schedule: http://www.apta.org/Payment/Medicare/CodingBilling/FeeSchedule/ o Note: The webinars listed under “Education” on this webpage discuss our advocacy efforts related to the PTA modifier and payment differential and next steps. • Additionally – we recently recorded a webinar with the PTA Caucus (several days prior to the release of the 2019 Medicare physician fee schedule final rule), discussing our advocacy efforts and next steps on the Medicare/PTA policy, as well as several other PTA-related topics: http://apta.adobeconnect.com/pzqnblg7b4k4/ • For information on the use of PTAs under Medicare, please visit: http://www.apta.org/Payment/Medicare/Supervision/UseofPTAs/ • For information/updates on the use of PTAs under TRICARE, please visit: http://www.apta.org/Payment/TRICAREVA/ Our advocacy on this issue is being led by our regulatory and congressional affairs teams. If you would like to learn more about their specific efforts, or have any additional questions, please contact advocacy@apta.org. Hope this helps!

      Posted by APTA Staff on 12/19/2018 8:21 AM

    • Can you verify that PTA/OTA outpatent services provided at a CAH will not have reduced payments per Section 53107 of the BBA of 2018, section 1834(v)(1)? There is also a reference to 1834(g) of the act. AOTA addresses this, but I am having trouble finding this information at APTA to confirm.

      Posted by Karen Northrop -> AMS_= on 1/8/2019 3:28 PM

    • @Karen: Thanks for the question! This is correct. APTA references this in our 2019 fee schedule final rule part 1 fact sheet: http://www.apta.org/Payment/Medicare/CodingBilling/FeeSchedule/FactSheet/2018/11/29/ As well as our 2019 Medicare Changes page under PTA payment differential modifier policy: http://www.apta.org/Payment/Medicare/2019/Changes/ Also, APTA will be developing a webpage on the modifier/differential policy once CMS releases more guidance later this year.

      Posted by APTA Staff on 1/9/2019 8:35 AM

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