Monday, November 23, 2015

AHCA/NCAL Submits Comments to CMS on Medicare Part-B Fee Schedule Incentive Programs

Dan Ciolek

AHCA/NCAL recently submitted comments  to CMS a Request for Information Regarding Implementation of the Merit-Based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models.

Briefly, when the MACRA Act of 2015 (Medicare Access and CHIP Reauthorization Act of 2015) eliminated the sustainable growth formula (SGR) for making annual adjustments to the physician fee schedule (PFS), which is used to pay SNFs for outpatient therapy services, it provided for fixed annual positive PFS payment updates through the end of 2018. After that date, only providers that participate and are successful in the quality-related and to-be-developed, MIPS or APM programs would be eligible for PFS payment adjustments. These new incentive programs would begin for physicians and some specified non-physician practitioners in 2019, and then potentially be extended to other eligible professionals (EPs), including physical therapists (PTs), occupational therapists (OTs,) and speech-language pathologists (SLPs) as early as 2021.

However, in this RFI, CMS proposes to build the MIPS and APM incentive programs for the future PFS model upon the foundation of the existing Physician Quality Reporting System (PQRS), Value-Based Payment Modifier (VM), and Electronic Health Records (EHR) Incentive Program that are to be eliminated with the onset of the MIPS and APM.

In the AHCA/NCAL comments, we note that while CMS recognizes PTs, OTs, and SLPs that work in facility-based provider settings (including SNF) as Eligible Professionals, they have historically excluded SNF therapists from participating in PFS incentive programs due to technology limitations rather than statutory restrictions. In the two specific recommendations, we are asking that CMS include SNF PT, OT, and SLP Medicare Part B therapy services paid under the PFS to be eligible for MIPS or APM adjustments when they become eligible per the MACRA 2021 timeline, and that CMS work with stakeholders to overcome the technological barriers that have prevented SNF therapy providers from participating in PFS incentive programs to date.

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