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Recently, the American Physical Therapy Association (APTA) shared their highlights of the 2014 Proposed Physician Fee Schedule Rule. This summary boils down the 605-page proposal from the Centers for Medicare and Medicaid Services (CMS) into a 16-page bulleted outline. The breakdown is incredibly helpful, and we definitely recommend you read it. However, we know that not everyone is an APTA Member, and many of you are crunched for time. So, we sat down with our Founder and PT Heidi Jannenga to develop an even more condensed rundown of the pros and cons of this proposal—a synopsis of the synopsis, if you will. 

Remember, if passed, this rule will directly impact you and your practice. Thus, we absolutely must clamor for the pros and boisterously oppose the cons. With this in mind, let us emphasize that this proposal is simply that: a proposal. None of these rules are law—yet. We can impact the outcome of every single item CMS has proposed.

How? If you’re an APTA Member, then you have until September 6, 2013, to submit comments in response to this rule. The APTA will gather those comments and submit them on behalf of its members.

If you’re not an APTA Member, then you can submit comments using one of the four methods listed on page two of the full CMS proposal. You can also share your thoughts in the comments section below. Heidi, who is a member of the APTA, will then include your feedback in the comments she submits to the APTA.

Pros

  • Nothing would change regarding the therapy cap or functional limitation reporting.
  • There would be a net increase of 1% to the total allowable charges for physical and occupational therapy.
  • There is potential for a new payment under the fee schedule for complex chronic care management services starting in 2015. This change could allow for better management of services for patients with complex chronic conditions that put the patient at “significant risk of death, acute exacerbation/decomposition, or functional decline.”
  • Revised regulations regarding payment for “incident to” services would require any individual performing ‘incident to’ services to meet “applicable state requirements to provide the services, including licensure.” While we’re not fans of physician-owned physical therapy services (POPTS), we view this legislation as a good thing because it prevents physicians from billing under their own names for therapy services provided by in-house personnel who may or may not be qualified to perform such services. This ensures physicians are hiring licensed physical therapists to provide therapy services. The proposed legislation also would reduce incidences of fraud and would elevate the standard of care for PT services within POPTS.  
  • Group Physician Reporting Option (GPRO) would be available again in 2014, allowing two or more providers in the same practice to submit their PQRS measures as a group, as long as the practice submits via a registry.
  • For both claims-based and registry-based PQRS, individual eligible professionals would be required to report on each measure for at least 50% of the eligible professional's Medicare Part B FFS patients. To compare, those submitting PQRS via registry in 2013 had to report on 80% of qualified patients.
  • For registry-based PQRS, CMS proposes that eligible professionals complete PQRS not only for Medicare patients, but also for those using Medicare replacement and advantage plans. Why is this good? More data hopefully means better payment structures in the future. And if you’re filing PQRS through a certified registry, then your PQRS data will have a direct impact on forthcoming CMS decisions.
  • In calendar year (CY) 2014, providers who satisfactorily report data on PQRS quality measures will earn a 0.5% incentive payment on their total allowed charges during the reporting period.
  • According to this proposal, CMS is working toward eliminating claims-based PQRS entirely, beginning in the CY 2017 reporting period. This would be beneficial to the therapy industry because it would lead to the collection of higher-quality patient data with less chance for error. Furthermore, registry-based reporting is far less time-consuming for the provider.
  • CMS also plans to continue expanding and improving the Physician Compare Website, an online resource that makes PQRS data available to the public as required by the Affordable Care Act.

Cons

  • “Due to the flawed SGR [sustainable growth rate] formula, CMS projects that the physician fee schedule update for CY 2014 is estimated to be negative 24.4%.” Barring government action, that means this rule could reduce your fee schedule by almost a quarter of its total value. Congress may avert this cut—as it has in recent years—but it is up to us and other organizations to convince our government representatives to stop this payment reduction. If they succeed in doing so, “the rule on outpatient physical therapy services in aggregate would be a positive 1% in 2014.”
  • In 2013, CMS required practitioners to report at least three measures for PQRS. However, they’re proposing the following changes for 2014:
  • For claims-based reporting, individual eligible professionals will report:
    • at least nine measures, covering at least three of the National Quality Strategy domains
    • one to eight measures if fewer than nine measures apply to the eligible professional
  • For registry-based reporting, individual eligible professionals would report:
    • at least nine measures, covering at least three of the National Quality Strategy domains
  • Penalties for failing to successfully participate in PQRS will begin in CY 2015 and will be based on CY 2013 data, while penalties for CY 2016 will be based on CY 2014 data.
  • According to this rule, beginning in 2014 you must report on at least 50% of your patients in order to avoid the penalty. (In 2013, you only needed to report on one patient to avoid the penalty.)
  • There you have it: the pros and cons. Now take action. Share your feedback on the proposal in the comments section below as well as through one of the routes listed above.
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