Thursday, March 20, 2014

Therapy Caps - ABNs May Be Needed on April 1st

Dan Ciolek

The current legislative provisions that provide an exceptions process to the Medicare Part B therapy caps, and enable providers to furnish medically necessary therapy services beyond $1,920 per calendar year to beneficiaries are due to expire on March 31 unless Congress acts before then. These services include physical therapy (PT), occupational therapy (OT), and speech-language pathology (SLP) services. SNF administrators and therapists should be aware of, and make preparations in case Congress does not repeal the therapy caps or extend the exceptions process by April 1, 2014.

AHCA is providing this information to alert members to be prepared for the possible return of a hard cap on therapy services. If this occurs, any therapy services furnished on and after April 1 that are above the annual $1,920 cap threshold will not be considered a covered Medicare service. SNF providers would need to properly inform affected beneficiaries of the change in Medicare policy and of their plan of care and payment options going forward.

It may be useful for administrators and therapists to review the CMS Advance Beneficiary Notice of Noncoverage (ABN) policy (see links below) so that you are prepared to comply with the beneficiary notification requirements should the “hard caps” return. We have requested that CMS provide any necessary updates to the FAQ as soon as possible if this situation occurs. Currently, with the exceptions process in place, SNF providers should not routinely issue ABNs to beneficiaries above the cap threshold. You may contact Dan Ciolek at AHCA if you have any questions.

Here are some useful CMS Links regarding Therapy Caps and Advance Beneficiary Notice of Noncoverage (ABN):

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