Wednesday, September 03, 2014 APTA Comments on PFS, HHPPS, OPPS, DMEPOS Proposed Rules The 2015 physician fee schedule (PFS), home health prospective payment system (HHPPS), outpatient prospective payment system (OPPS), and durable medical equipment prosthetics, orthotics, and supplies (DMEPOS) are the subjects of newly available APTA comments on proposed rules from the Centers for Medicare and Medicaid Services (CMS). In the PFS letter (.pdf), APTA raises concerns about the therapy cap and urges timely congressional action. The association also writes that while it supports improved transparency in the valuation of current procedural terminology (CPT) codes, CMS should hold off on implementation of any changes until 2017 and should allow the CPT Editorial Panel to continue its work to develop a new coding structure for the 97000 series. Other areas addressed in the letter include substitute physician billing arrangements (locum tenens), the Medicare Shared Savings Program, the physician quality reporting system (PQRS), and a CMS proposal to expand the value-based modifier program to nonphysicians. APTA's letter on the HHPPS (.pdf) makes recommendations on a number of issues, including urging CMS to reduce rebasing percentage cuts and to overhaul therapy payment under the HHPPS. The association also commends CMS on its efforts to simplify therapy reassessment by removing 13- and 19-day timeframes, and recommends that it extend timeframes to every 30 calendar days. A separate APTA letter on the OPPS (.pdf) requests that CMS remove physical therapy from the potential services packaged in the proposed comprehensive ambulatory payment classifications (APCs), and that the agency collect cost and utilization data on the proposed packaged ancillary services program and its effects on patient outcomes. The association also writes in support of a CMS-proposed revision to remove the physician recertification requirement for inpatient admission (with the exception of long stays and outlier cases). APTA's comments on the DMEPOS rule (.pdf) recognize CMS for its efforts to curb fraud, waste, and abuse but warn that "certain proposed changes … could impede or delay access to timely medically necessary care." The association recommends that CMS proceed carefully with any plans to move to competitive bidding and bundled payment approaches, and urges the agency to conduct pilot testing before implementing any broad program. CMS will consider all comments submitted and issue final rules for these settings on or around November 1, 2014.