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Written by: Darlene D'Altorio-Jones (1959-2015) on Wednesday, November 2, 2011 Posted in: Outpatient Rehab

The comment period for the 2012 Physician Fee Schedule payment for part B services passed August 30, 2011. The proposed rule CMS-1524-P was released in a final version Nov. 1 and will affect payments beginning January 1, 2012.

The rule covers:

– Reduction in payment rates (table 64); looking at Clinical Labor, Supplies Expense, Equipment Expense, Direct Practice Expenses/hour, Clerical Payroll, Office Expense, Other Expense and Indirect Practice Expenses/hour for 89 geographical regions initially established in 1997.

– Continued Multiple Procedure Payment Reductions (MPPR) for always therapy procedures initiated in the 2011 rule. (Listed below which maintains the 25% reduction for facility practices and 20% for non-facility practices. Types of facilities are defined in Title 42, Section 414.22)

– Review of potentially misvalued codes which includes 3 highly used therapy codes, 97140 (manual therapy), 97112 (Neuromuscular re-education) 97001 (PT Evaluation) – seeking AMA review for update in 2012 for 2013 application.

– Additional incentive programs for a 12 month quality reporting period yielding .5% incentive payments and e-prescribing for physician practices.

In addition, CMS finalized the 2013 reporting calendar year toward payment penalty in 2015 (very similar to time frames chosen for IRF full quality reporting and penalties).

The specific therapy cap exceptions process will expire on December 31, 2011, unless Congress acts to extend it. Given an extension continues, those rates will be set at $1,880 beginning January 1st 2012 along with the other payment updates described within the blog.

The final rule announces a 27.4% cut in Medicare payments for physicians, physical therapists, and other healthcare professionals based on a flawed sustainable growth rate (SGR) formula unless Congress takes action to prevent these cuts. IF the cut does NOT go into effect, regulatory impact of the work, practice expense, and malpractice RVU’s could net physical therapy payments by a positive 4.0%. Now more than ever it is time to contact your congressional leaders to discuss adverse impact on access to care; specifically for those facilities with a high percentage of Medicare Beneficiaries.

The MPPR policy will apply in all settings where outpatient therapy services are paid under Part B. This includes services paid under PFS furnished in the office setting, institutional services paid at the PFS rates furnished by outpatient hospitals, home health agencies, comprehensive outpatient rehabilitation facilities (CORFs), and other entities that are paid under Medicare Part B for outpatient therapy services. Codes affected in MPPR are listed in addendum H of the proposed rule and are those listed here (AMA CPT coding manual).

Addendum H–CY 2011 “ALWAYS THERAPY” SERVICES SUBJECT TO THE MULTIPLE PROCEDURE PAYMENT REDUCTION * CPT Code Short Descriptor

92506 Speech/hearing evaluation
92507 Speech/hearing therapy
92508 Speech/hearing therapy
92526 Oral function therapy
92597 Oral speech device evaluation
92607 Ex for speech device Rx, 1hr
92609 Use of speech device service
96125 Cognitive test by HCPro
97001 PT evaluation
97002 PT re-evaluation
97003 OT evaluation
97004 OT re-evaluation
97012 Mechanical traction therapy
97016 Vasopneumatic device therapy
97018 Paraffin bath therapy
97022 Whirlpool therapy
97024 Diathermy (e.g. microwave)
97026 Infrared therapy
97028 Ultraviolet therapy
97032 Electrical stimulation
97033 Electric current therapy
97034 Contrast bath therapy
97035 Ultrasound therapy
97036 Hydrotherapy
97110 Therapeutic exercises
97112 Neuromuscular re-education
97113 Aquatic therapy/exercises
97116 Gait training therapy
97124 Massage therapy
97140 Manual therapy
97150 Group therapeutic procedures
97530 Therapeutic activities
97533 Sensory integration
97535 Self care mgmt training
97537 Community/work reintegration
97542 Wheelchair mgmt training
97750 Physical performance test
97755 Assistive technology assess
97760 Orthotics mgmt and training
97761 Prosthetic training
97762 C/o for orthotics/prosthetics use
G0281 Electrical stimulation unattend for press
G0283 Electrical stimulation other than wound
G0329 Electromagntic tx for ulcers

Although this highly awaited final rule was just published, it is anticipated that for therapy practices the time has come to define and defend services from a value platform. Can practices provide services that effectively meet outlined results in a timely, efficient manner? At what point payment and outcome measures will be more directly related to functional outcomes obtained in therapy practices?

Although the final rule may not apply directly to timely, efficient care it is possible that further research, like that being conducted under DOTPA (Developing Outpatient Therapy Payment Alternatives), will provide guidance for therapy payments outside of Physician Fee Schedules and may relate more to the practice and outcomes of “Always Therapy” providers.