Wednesday, October 9, 2019

AHCA/NCAL Submits Comments to CMS Regarding Therapy and Telehealth Provisions in Physician Payment Proposed Rule

Dan Ciolek

On September 27, the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) submitted public comments to the Centers for Medicare and Medicaid Services (CMS) in response to the proposed rule briefly titled “Medicare Program; CY 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; [CMS-1715-P]” which can be found here.  Briefly, this proposed rule updates payment policies and payment rates associated with many services furnished under the Medicare Part B benefit that impact residents of skilled nursing facilities and assisted living residences.  The AHCA/NCAL comments letter focused on concerns related to the following three subject areas: 1) provisions related to the implementation of physical therapist assistant and occupational therapy assistant payment adjustment modifiers, 2) provisions related to adjustments in physician evaluation and management payments, and 3) provisions related to telehealth services in skilled nursing facilities (SNFs).

With regard to the specific proposed policies, AHCA/NCAL voiced grave concern with CMS’ proposed application of the CQ/CO modifier when outpatient physical therapy and occupational therapy services are furnished “in whole or in part” by a physical therapist assistant (PTA) or occupational therapy assistant (OTA) and how this policy, if finalized as proposed, will negatively affect Medicare beneficiary access and add administrative burden.  Additionally, AHCA/NCAL voiced concern about proposed changes to physician evaluation and management (E&M) payments that would result in a negative eight percent adjustment to outpatient therapy payment rates beginning CY 2021.  Finally, with regards to telehealth policy, AHCA/NCAL requested that the Secretary of Health and Human Service consider revising existing obsolete SNF telehealth frequency limitations promulgated through prior rulemaking as well as consider approaches to improve telehealth access to currently excluded geographic locations and to rehabilitation services furnished by  physical, occupational, and speech therapy professionals. 

During the comment period, AHCA/NCAL coordinated efforts with other professional, provider, and beneficiary organizations submitted joint letters and were able to secure meetings with CMS officials to provide additional details and examples related to these concerns, as well as to offer suggested alternative policy approaches.  Additionally, thousands of comment letters from AHCA/NCAL members and other therapy providers were submitted with a consistent message requesting revision of the proposed policies before finalization.  The final rule is typically published in November. 

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