CMS issued proposed rule, CMS-1590-P, on July 6, 2012 that includes a proposal to collect data on patient function related to physical and occupational therapy, and speech language pathology services. Section 3005(g) of the Middle Class Tax Relief and Jobs Creation Act (MCTRJCA) requires CMS to implement, beginning on Jan. 1, 2013, “… a claims-based data collection strategy that is designed to assist in reforming the Medicare payment system for outpatient therapy services subject to the limitations of section 1833(g) of the Act. Such strategy shall be designed to provide for the collection of data on patient function during the course of therapy services in order to better understand patient condition and outcomes.”
The proposed rule will appear in the July 30, 2012 Federal Register. CMS will accept comments on the proposed rule until Sept. 4, 2012, and will respond to them in a final rule with comment period to be issued by Nov. 1, 2012.
If all goes as proposed, therapists in outpatient settings will begin adding new codes to a Medicare patient’s bill or payment claim form on Jan. 1, 2013. These new codes will be related to and describe the patient’s functional impairment for which treatment is requested; the status of that impairment at beginning, during and the end of care, and the goal to be achieved in treating the impairment. Without a classification system in place, CMS is attempting to capture and understand the Medicare beneficiary population that uses therapy services, how their functional limitations change as a result of therapy services, and the relationship between beneficiary functional limitations and furnished therapy services over an episode of care. All this in preparation for developing an alternative to Medicare’s currently capped therapy fee for service payment methodology.
For many therapists, this sounds simple enough as it mirrors existing clinical practice of assessing a patient’s functional status, identifying and measuring the problem, setting treatment goals, and documenting progress towards discharge outcome. The difference will be in how the process gets documented and reported. Specific codes to be known as G Codes will be assigned for each of these steps in the process. G Code sets will eventually be created specifically for diagnoses/conditions and functional limitation categories.
Applying and reporting the appropriate codes will be the new learning requirement that will significantly impact practice and clinical operations. However, more importantly it will begin a stream of electronic data to feed the analysis of therapy use and effectiveness that will ultimately determine payment. Now is the time to become informed and voice your opinions to these proposed changes. The comment period is underway; you may access the proposed rule here on the CMS website.