Be Careful What You Wish For…

Posted by Marsha Lawrence, PT, CHT; ASHT Practice Division Director & ASHT CMS Task Force Chairperson on 07/14/2016

In case you have been lucky enough to be on vacation for the past two months or just managed to avoid the news, CMS released the newest initiative to change the way healthcare providers are being paid under Medicare Part B. The Medicare Access and Chip Reauthorization Act (MACRA), passed last year, repealed the pesky Sustainable Growth Rate (SGR) formula (much to our delight) and allowed exceptions to the Medicare Therapy Cap to continue through December 31, 2017.  ASHT advocated complete repeal of the therapy cap, but an extension of the exceptions rule was better than a “hard cap.”

What was less known was that MACRA also directed CMS to develop a new payment plan within a year, moving from a “fee-for-service” payment model to a “quality-based” payment model for Medicare beneficiary payments. CMS’ response, the Quality Payment Procedures rule (QPP), was released at the end of April and had a 90-day comment period, allowing for public feedback on the proposed rule. During this same period, Andy Slatkin, the CMS Acting Administrator, embarked on an “informational tour,” promoting the plan to large medical and healthcare administration professional organizations. The response from provider groups was lukewarm at best, while the response from healthcare administrators and private payers was more favorable. CMS received more than 4,000 comments by June 27, most of which were critical of the proposed QPP.*

Two congressional committees held separate hearings during which members from both sides of the aisle expressed concerns over the potential secondary impact on patient access to services under the proposed rule.

ASHT reached out to other professional organizations and formed a joint taskforce with the Academy of Hand and Upper Extremity Physical Therapy (formerly the APTA Hand Rehabilitation Section) to review the rule and its potential impact on hand therapy practice, and to explore developing quality measures aligned with services provided by hand therapists. Based on the review of the 900+ page document by the Federal and State Regulations Committee of the Practice Division (acronym dictionaries in hand!), the taskforce identified potential concerns and advised the ASHT Board of Directors in their response to CMS, which was submitted June 27.  

The taskforce determined that the development of quality measures was a much larger task than initially realized and while ASHT may not be able to independently develop and pilot test quality measures, taskforce members were able to suggest examples and offered to partner with CMS to identify additional measures reflecting the services provided by hand therapists.

CMS will review the submitted rule responses and release a final rule, usually by the middle of November. The QPP is set to begin January 1, 2017 for physicians, nurse practitioners and other designated providers. No firm date has been released for including therapy in the rule, but based on its complexity, now is the time to start reviewing it and its potential impact on your practice. ASHT has a brief summary on our website and will provide updates when additional information is available.

*Dickson V. MACRA rule raises patient privacy concerns. Modern Healthcare June 28, 2016. http://www.modernhealthcare.com/article/20160628/NEWS/160629914 accessed June 29, 2016

A very special thank you to the ASHT CMS Task Force who stepped up with very short notice to provide input to the CMS letter:

Marc Bartholdi, OTR/L, CHT, OTD
Nancy Cannon, OTR, CHT
Elizabeth de Herder, OTR/L, CHT
Mia Erickson, PT, CHT, EdD, ATC
Stacy Hite, PT, DPT, MS, CHT
Marge Krengel, OTR/L, CHT
Ann Lucado, PhD, PT, CHT
Laurie Rogers, MS, OT, CHT

Submitted by Marsha Lawrence, PT, CHT, 
ASHT Practice Division Director
ASHT CMS Task Force Chairperson