Tuesday, September 11, 2018

AHCA/NCAL Submits Comments on CY 2019 Medicare Part B Fee Schedule Proposed Rule

Dan Ciolek

On September 10, AHCA/NCAL submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to a July 27, 2018 Notice of Proposed Rulemaking (NPRM) pertaining to the calendar year (CY 2019) Medicare Part B Physician Fee Schedule.  Medicare Part B pays for physician services, physical, occupational, and speech therapy services, some equipment and supplies, and some drugs and biologics furnished to outpatients, and under consolidated billing provisions, also pays SNFs for therapies for residents that are not otherwise eligible for Part A coverage.    

The AHCA/NCAL comments focused on five areas:
  1. Therapy Services – CMS proposed several policies related to coding and payment Part B therapy for therapy assistants that are required as part of the pay-for’s for the therapy cap repeal legislation passed earlier this year in the Bipartisan Budget Act of 2018 (BBA).  AHCA/NCAL recommended improvements to the definitions of key new terminology to make the policy clearer, and to protect access for patients with more complex needs.  On an unrelated therapy issue, CMS proposed to eliminate burdensome and ineffective reporting requirements related to function.  AHCA/NCAL supported the proposed elimination of the burdensome and unnecessary requirements.
  2. Communication Technology-Based Services – CMS proposed new telecommunication-based codes that fall outside of Medicare telehealth legislation limitations as well as discussed potential changes to existing telehealth policies.  AHCA/NCAL commented on opportunities to increase communication technology-based services for SNF residents, and to reduce SNF telehealth limitations so that they are consistent with other inpatient rehabilitation facility (IRF) and long term care hospital (LTCH) post-acute care (PAC) provider settings.
  3. Physician E&M code policy changes – CMS proposed reducing some documentation burden on office-based services and also collapsing payment rates for the highest intensity evaluation and management services (which impacts geriatricians and other specialties that commonly care for the disables and elderly and SNF residents).  While not directly impact physician services furnished in the SNF, the policy could discourage physicians from working with this growing population hurting the available SNF physician workforce.  AHCA/NCAL spoke to these concerns.
  4. Updates to the Part B fee-schedule-based Quality Reporting Program – CMS has not recognized facility-based Part B therapy services/therapists (including SNF) as being eligible for the Part B merit-based incentive payment system (MIPS) and alternative payment models (APM) fee schedule-based incentive programs, although PTs and OTs in private practice will become eligible if the rule is finalized.  AHCA/NCAL cited concerns that this oversight will create unbalanced quality and payment systems as nearly two-thirds of therapy providers (including SNF) will remain ineligible for the quality incentives, and suggested an approach to move towards making this happen in the future.
  5. Request for Information on Interoperability – This is the same request that AHCA submitted comments for in the recent SNF PPS FY 2019 NPRM.  AHCA/NCAL reiterated and updated those previously submitted comments that cited funding concerns, and offered practical suggestions to encourage increased operability without adding unnecessary administrative burdens.   
Please contact AHCA’s Associate Vice President, Therapy Advocacy Dan Ciolek if you have questions.

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