Practice Management Updates

Call on Congress to Stop Payment Reductions for Therapy Services for Medicare Beneficiaries
(August 5, 2020)

On August 3, 2020, the Centers for Medicare and Medicaid Services (CMS) released its proposed 2021 Medicare Physician Fee Schedule. The rule recommends significant payment reductions to more than three dozen healthcare professions, including occupational and physical therapy. 

CMS is using the revenue from these cuts to offset an increase in payments for physicians. These cuts are the result of a Medicare statutory requirement known as "budget neutrality," which requires that any increase in costs to the Medicare program must result in decreased spending elsewhere in the Medicare program. The CMS proposal would cut reimbursement for Medicare Part B therapy codes (including 97165, 97110 and 97161 for example) by an estimated 9 percent. 

ASHT, the American Occupational Therapy Association and the American Physical Therapy Association have been actively raising concerns with Congress and CMS about the impact these cuts have on providers and patients in need of care, particularly amidst the COVID-19 pandemic. 

Fortunately, bipartisan legislation has been introduced in the House of Representatives (H.R. 7154, the Outpatient Therapy Modernization and Stabilization Act) by Reps. Boyle (D-PA) and Buchanan (R-FL) that would prevent these proposed reimbursement cuts by waiving the statutory budget neutrality requirements. 

ASHT will continue to advocate against these cuts with CMS, but we need you to take action now by asking your members of Congress to intervene to stop these payment reductions. 

Read the full CMS Proposed Rule and Fact Sheet

Telehealth Implementation Checklist
(July 10, 2020)

ASHT has compiled the following checklist to help guide the implementation of telehealth into your organization of practice. Before you begin providing services via telehealth or using telecommunications modalities, we encourage you to consider federal and state legislation and regulations that govern practice, billing and coding issues, as well as hardware and software requirements.

Telehealth and COVID-19
(May 14, 2020)

ASHT is providing the following list of resources to assist members with implementing telehealth services. Resources include webinars, FAQs, coding and billing guidelines and reimbursement information.

American Occupational Therapy Association

American Physical Therapy Association

Centers for Medicare and Medicaid Services

American Medical Association

Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS): CMS Flexibilities to Fight COVID-19 Update
(April 7, 2020)

Submitted by: Angela M. Stephens, DHS, OTR/L, CHT

In response to the COVID-19 pandemic, there are several temporary changes across the entire U.S. healthcare system.  These changes will be immediate and will be in place during the emergency declaration time period. In summary, the goals for this action are:

  • Ensure local hospitals and health systems have the capacity to handle the patient volume due to COVID-19, temporary expansion sites.
  • Remove barriers for physicians, nurses, and other clinicians to be readily hired to meet the healthcare demand
  • Increase access to telehealth in Medicare
  • Expand in-place testing
  • Patients Over Paperwork, to allow focus on patient care for Medicare and Medicaid beneficiaries that may be affected by COVID-19

Patients Over Paperwork

Patients Over Paperwork will allow DME Medicare Administrative Contractors the flexibility to waive replacement requirements for DMEPOS.  However, the claim must include a narrative description from the DMEPOS supplier as to why a replacement was warranted.  The DMEPOS Medicare Prior Authorization program has been paused for certain items.  CMS is not requiring accreditation for newly enrolled DMEPOS providers, and the expiring supplier accreditation is extended for 90-days.  The “proof of delivery” signature requirement has been waived by CMS for both Part B drugs and DME.  Documentation should be placed in the medical record stating date of delivery and that the signature could not be obtained.  In addition, CMS has expanded the Accelerated and Advance Payment Program.  Medicare providers should submit the request to the appropriate Medicare Administrative Contractor (MAC).  Each MAC will then review the request and issue payments within 7 calendar days of receipt dependent upon the provider has met the required qualifications.  A fact sheet has been developed by CMS and can be viewed on this link:

Medicare Appeals in Fee For Service (FFS), Medicare Advantage (MA), and Part D

CMS is allowing MACs and Qualified Independent Contractors in certain FFS programs, MA, and Part D plans to allow extensions to file appeals and to process appeals with the flexibilities that are available if good cause requirements are met.  In addition, some FFS programs are permitted to waive requirements for timeline requests of additional information to adjudicate appeals.  Medicare Advantage plans may extend time frames by 14 calendar days to adjudicate determinations and reconsiderations for medical items and services based upon certain requirements.  For more detailed information please review this link: