Fewer than 48 hours after the launch of a new Medicare payment system for skilled nursing facilities (SNFs), APTA began receiving word from physical therapists (PTs) and physical therapist assistants (PTAs) that a number of providers were announcing layoffs or shifts to PRN roles with reduced hours and fewer or no benefits. Many were told by their employers that the new system, known as the Patient-Driven Payment Model, or PDPM, was the reason for reduced staffing levels and less therapy.
There's one problem with that explanation: it isn't true.
That's the message APTA is delivering to SNFs, association members, and the media as it works to debunk myths surrounding a system that was designed to support clinician decision-making and push SNFs toward a more patient-focused payment model.
"Yes, this is a new payment system, but it doesn’t change the reality that staffing and service delivery must continue to be grounded in quality patient care," said Kara Gainer, APTA's director of regulatory affairs.
What PDPM changes—and what it doesn't
The US Center for Medicare and Medicaid Services (CMS) describes the PDPM as an attempt at "better aligning payment rates…with the costs of providing care and increasing transparency so that patients are able to make informed choices." In that sense, PDPM is another step in the overall evolution of health care toward a more outcome-based, patient-focused system. And it didn’t arrive out of nowhere: CMS has been floating proposals for revamping SNF payment since at least 2017.
Still, the new system, with its basis on classifying SNF residents among 5 components (including physical therapy) that are case-mix adjusted and employing a per diem system that can be adjusted during a patient's stay, marks a big change for SNFs. For SNFs that embraced volume-based approaches to care, the shift is even more significant.
That may be true, Gainer said, but some of the most important elements of PDPM are the things that haven't changed under the new system.
"Absolutely nothing changed between September 30 and October 1 [the startup date of PDPM] about patient needs in SNFs, or the value of physical therapy in meeting those needs," Gainer said. "PDPM is predicated on the idea that rehabilitation professionals will exercise clinical judgment and furnish reasonable and necessary services to patients."
APTA created a 1-page handout that summarizes what's different about the PDPM—more patient focus, reduced administrative burden, a new definition of group therapy and a 25% combined limit on group and concurrent therapy, and a new way to determine function scores—but the resource also points out what remains unchanged: medically necessary care as a baseline standard, the criteria for skilled therapy coverage, and the centrality of clinical judgment, among other elements. Additionally, the need for daily skilled nursing services or rehabilitation services has not changed.
The bottom line, according to Gainer, is that decisions that override clinical judgment and reduce or compromise patient care shouldn't be attributed to any requirements contained in PDPM.
"Assertions that the PDPM mandates cuts in care are untrue, as are claims that PDPM requires the maximum use of group or concurrent therapy, sets out productivity requirements, and dictates how many minutes of care therapists can provide based on payment categories," Gainer said. "Whether deliberate or simply a misinterpretation of the rule, these myths need to be put to rest."
A big incentive for SNFs to get past the myths: CMS is paying attention
As APTA members began sharing their stories of layoffs and status shifts attributed to PDPM, APTA President Sharon Dunn, PT, PhD, took to Twitter with a simple message:
"PDPM changed Medicare payment methodology for SNFs on Oct 1. It did not change the value of physical therapy services or patient needs. Reducing PT and PTA staff 46 hours into this model reflects poorly on the commitment to patient access and quality of care. And CMS is watching."
SNFs should pay particular attention to the last sentence of Dunn's tweet, Gainer said.
"Anyone who's followed CMS rulemaking over the past few years knows that patient outcomes data and their link to plans of care are becoming extremely important in how CMS shapes payment and other rules—and rightly so," Gainer said. "CMS has already indicated to us that they are closely monitoring the actions of health care facilities post-PDPM to determine if patient needs are driving decision-making, and may propose changes to counter any trends that impede the overall goals of the system."
In an interview for an article on PDPM published in Skilled Nursing News, Robert Lane, a consulting director for health care consulting firm BKD, called the SNF layoffs and adjustments "premature," and stated his surprise that the SNFs didn't "pump the brakes a little for 90 days to see where we're at after the first quarter, couple of billing cycles."
And like Gainer, Lane told Skilled Nursing News that it's certain the sudden drastic changes will "draw attention from CMS."
APTA, the American Occupational Therapy Association, and the American Speech-Language-Hearing Association have issued a joint statement noting that they have shared reports of layoffs directly with CMS and will continue to keep the agency abreast of reductions that put patients at risk.
APTA's continued work
The first versions of what evolved into PDPM emerged in spring of 2017, and APTA immediately began advocating to CMS on behalf of patients and the physical therapy profession. The association's efforts, fueled by member engagement, led to some significant changes to the final rule—including CMS' decision to implement a combined limit of 25% of group and concurrent therapy.
But now, with PDPM in place, APTA's efforts need to shift to careful monitoring of how the rule is being interpreted and implemented, and its impacts on patient care and the PTs and PTAs providing that care. The reason is simple, according to Gainer: rules can be changed.
"Another myth that's being circulated is that the PDPM is now written in stone and that no adjustments can be made," Gainer said. "That has never been the case with rules from CMS, and certainly isn't the case with this system—especially given the amount of attention CMS will be paying to how SNFs interpret and implement PDPM, and the degree to which those changes impact patient access to medically necessary care."
Get the facts on PDPM and stay up-to-date on news about the new system: visit APTA's Skilled Nursing Facility and Home Health Payment webpages. Do you have your own story about how the PDPM has affected your work? Contact firstname.lastname@example.org.