For most PTs, coding for service charges is kind of an afterthought—something they do at the end of the day, after they’ve finished up all of their paperwork. It’s a task that—while not the most exciting endeavor—is fairly straightforward: find the CPT code that matches the service provided, calculate the correct number of units, record everything appropriately, and move on to bigger and better things (i.e., treating and healing patients). But, in less than a year, that mundane-yet-simple process could get a whole lot more complicated. That’s because on January 1, 2017, the evaluation portion of the APTA’s proposed Physical Therapy Classification and Payment System (PTCPS) is slated to take effect—with the intervention portion tentatively following close behind on January 1, 2018.
In parts one and two of this three-part special report, I detailed the history and philosophy behind PTCPS and provided a breakdown of the concerns it has generated among industry leaders. Of course, discussion around any healthcare reform-related topic can easily spiral into an endless rabbit hole of speculation and theorization—two things that most time-pressed PTs just don’t have room for in their schedules. So, in this final post of the series, I want to focus on the absolutes—that is, the facts therapists simply can’t afford to ignore. So, without further ado, here’s why rehab therapists should care about PTCPS:
1. It will require training and software upgrades.
Make no mistake about it: this is not merely a CPT coding refresh. It’s a whole new system with a whole new set of code options and a whole new code selection logic. For the first time ever, therapists will have to consider the severity and complexity of their patients as they code for the treatments provided—and that means therapy providers are going to need in-depth training on how to make accurate and appropriate code selections. Plus, with any new system comes new rules and regulations, and the burden of complying with those regulations rests on the providers using the system. It’s a massive educational undertaking—one that should be on therapists’ radar now. Furthermore, the impending change already should be on the radar of EMR and billing software companies, as they’ll need to update their systems to accommodate the new codes. (And that might prove tricky considering that the codes themselves have yet to be released to the public.)
2. It will change the way therapists document and bill.
Documentation already plays a crucial role in supporting the services—and the medical necessity of those services—that therapists provide and bill for. But, PTCPS adds another layer of coding criteria: patient severity and complexity. And that, in turn, adds another layer to therapists’ documentation requirements. Furthermore, according to Jeff Hathaway, the president of the Physical Therapy Business Alliance (PTBA), the proposed system removes the time element from service coding—which brings up concerns over how Medicare and other payers will manage the new, session-based codes. After all, many existing regulations are based on time. “The concern is that Medicare is going to assign time,” Hathaway said. Whether these factors will make documentation a more arduous undertaking has yet to be seen (though, as I explained in part two, that’s the effect many industry leaders are predicting). What is certain is that documentation will change—and that alone could prove arduous enough to throw a major wrench in clinic operations.
3. No one knows how it will impact payments.
The basic idea behind the severity/complexity aspect of PTCPS is that it will allow providers to “better demonstrate [to stakeholders] how therapists go about their clinical decision-making,” Carmen Elliott, APTA’s senior director of payment policy, recently told WebPT. Theoretically, that would allow payers to recognize the true value physical therapists provide. But many say the link between severity/complexity and value is weak, at best—which actually could lead to decreased payment rates. “No one has been able to articulate exactly how [this proposal] moves us closer to showing our value or moves us to a better place to play in the value-based payment systems,” Hathaway and PTBA board members Larry Benz and John Childs wrote in a joint statement to WebPT. “[It] may lead to lower payment…[and] may set back our ability to showcase our value in alternative payment systems based on value.” And according to Hathaway, that should should raise more than a few eyebrows among those in the therapy community. “When you look at the cost landscape of PT and ask people, ‘What is the number-one thing you’re concerned about?’, the answer you’re typically going to get is, ‘Payment,’” he said. “Well, the core of how we get paid is CPT coding...and here, we have a fundamental shift to coding and no one can answer how it will impact payment. That puts a lot of things in limbo, and it should be a serious concern to every practitioner.”
4. It will set the tone for future payment reform efforts.
Value is a hot buzzword in today’s healthcare arena. In fact, it forms the basis of the so-called triple aim of healthcare reform: higher-quality care at a lower cost with better patient satisfaction. Thus, many PT industry leaders believe it should form the basis of any physical therapy payment reform initiative. That way, PTs can be sure they’re evolving their profession in a way that sets them up for success in the long term. But, considering that the proposed coding system does not directly account for value (i.e., by incorporating outcomes as a payment factor), some question whether it will lead PT payment reform efforts down a path that will prevent rehab therapists from participating in the value-driven payment and care delivery models of the future.
“[PTCPS] rewards the wrong thing,” Hathaway said. “It all comes down to dollars, and our biggest ROI in terms of care is preventing unnecessary care. With the intensity/complexity model, that’s not rewarded.” And while adding an outcomes element to the proposed system is something that, in Elliott’s words “could be considered [in the future],” Hathaway doesn’t see a reason to wait: “I think [outcomes] should be part of it from the beginning, because my experience with this field is that what we hope to do doesn’t happen,” he said. That’s why he urges those in the therapy community to take an interest—and a stand—on this issue. “If the majority comes to some sort of conclusion, that has to be listened to,” he said. “It’s your duty to ensure the profession is viable…[and] if we can take a giant step, why not?”
Inspired to make your voice heard? Check out the Take Action section of the Alliance for Physical Therapy Quality and Innovation (APTQI) website. (PTBA recently joined this organization, which advocates for payment reform rooted in value and quality.) Have a question or comment? Share your feedback in the comment section below, and let’s keep the payment reform conversation going.
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