WEBVTT 00:00:18.432 --> 00:00:20.455 So we do have an initial 00:00:20.495 --> 00:00:21.858 reaction to the fee schedule, 00:00:21.878 --> 00:00:22.599 which was published. 00:00:24.321 --> 00:00:27.125 It will actually be finally 00:00:27.184 --> 00:00:28.928 published at the end of August. 00:00:29.528 --> 00:00:29.689 Sorry, 00:00:29.708 --> 00:00:31.131 at the end of July in the Federal 00:00:31.170 --> 00:00:31.571 Register. 00:00:31.611 --> 00:00:33.094 But what CMS does and a 00:00:33.113 --> 00:00:34.316 whole bunch of other agencies do 00:00:34.756 --> 00:00:35.536 is they produce a 00:00:35.656 --> 00:00:37.557 pre-publication copy to 00:00:37.597 --> 00:00:38.497 give folks a little bit 00:00:38.537 --> 00:00:39.738 more time to look at it. 00:00:39.779 --> 00:00:40.899 They look very different in 00:00:40.939 --> 00:00:42.000 terms of formatting and 00:00:42.020 --> 00:00:42.640 that kind of stuff, 00:00:43.020 --> 00:00:43.820 but it just gives us more 00:00:43.841 --> 00:00:45.521 of an opportunity to really 00:00:45.561 --> 00:00:47.701 dive in and try to understand it. 00:00:47.762 --> 00:00:50.423 So that goes on display. 00:00:50.664 --> 00:00:52.024 And what's also nice that 00:00:52.045 --> 00:00:53.225 CMS did is because of the 00:00:53.265 --> 00:00:54.585 importance of this regulation, 00:00:55.185 --> 00:00:56.326 They also produced a whole 00:00:56.347 --> 00:00:57.548 bunch of background materials, 00:00:58.347 --> 00:00:59.308 other things explaining 00:00:59.348 --> 00:00:59.948 what they're trying to 00:01:00.009 --> 00:01:01.369 accomplish within the fee schedule. 00:01:01.409 --> 00:01:03.652 So the top line is we're still bummed. 00:01:03.951 --> 00:01:05.332 We're still frustrated 00:01:05.673 --> 00:01:07.493 seeing red while you try to 00:01:07.534 --> 00:01:10.115 get in the black with the 00:01:10.156 --> 00:01:11.337 cuts in the fee schedule. 00:01:11.356 --> 00:01:12.918 There is a statutorily 00:01:12.977 --> 00:01:15.840 mandated 2.8 percent cut 00:01:16.180 --> 00:01:17.740 that CMS had to implement 00:01:18.120 --> 00:01:19.462 based on what Congress gave 00:01:19.501 --> 00:01:21.424 them for an appropriation 00:01:21.623 --> 00:01:23.105 and really an entitlement. 00:01:23.144 --> 00:01:24.665 But the money just wasn't there. 00:01:25.486 --> 00:01:26.566 in order for CMS to do 00:01:26.667 --> 00:01:27.906 anything but create that cut. 00:01:27.927 --> 00:01:29.707 So CMS is sort of in a box 00:01:30.248 --> 00:01:31.447 and it's why it's so 00:01:31.507 --> 00:01:32.367 important for folks to 00:01:32.429 --> 00:01:33.968 engage in congressional 00:01:34.049 --> 00:01:35.269 advocacy on the payment cut 00:01:35.349 --> 00:01:36.890 as well as stuff with CMS 00:01:37.510 --> 00:01:39.311 because Congress sets that rule, right? 00:01:39.350 --> 00:01:40.010 There's a sort of, 00:01:40.111 --> 00:01:40.930 the way that it works is 00:01:41.712 --> 00:01:42.951 Congress produces the 00:01:43.012 --> 00:01:44.231 skeleton and the regulatory 00:01:44.272 --> 00:01:45.912 agencies produce the flesh, right? 00:01:46.173 --> 00:01:50.296 And so this is an expression of that, 00:01:50.596 --> 00:01:52.418 happens every year, and it's really, 00:01:52.457 --> 00:01:53.399 really critical to know 00:01:53.819 --> 00:01:54.439 what it's gonna do. 00:01:54.500 --> 00:01:55.721 So overall, 00:01:55.721 --> 00:01:59.384 2.8% cut across the board for 00:01:59.483 --> 00:02:01.245 all specialties who use Part B. 00:02:02.721 --> 00:02:05.224 So that's physicians, that's nurses, 00:02:05.304 --> 00:02:06.745 that's a whole bunch of 00:02:06.766 --> 00:02:07.826 other folks who are in the 00:02:08.086 --> 00:02:08.646 healthcare profession 00:02:08.667 --> 00:02:09.668 that's not hospitals. 00:02:11.090 --> 00:02:13.551 But it is, you know, the caregivers, 00:02:13.853 --> 00:02:14.332 I would argue. 00:02:14.393 --> 00:02:16.294 And so very frustrating. 00:02:16.754 --> 00:02:18.296 We'll push back against it, like I said, 00:02:18.356 --> 00:02:18.937 with Congress. 00:02:19.758 --> 00:02:20.558 And then hopefully, 00:02:20.679 --> 00:02:21.659 just like last year and the 00:02:21.680 --> 00:02:22.781 year before and the year before, 00:02:23.080 --> 00:02:24.222 we'll be able to blunt that 00:02:24.301 --> 00:02:27.944 cut and make sure that in the lame duck, 00:02:27.965 --> 00:02:29.145 that there will be some 00:02:29.567 --> 00:02:31.247 movement in terms of 00:02:31.709 --> 00:02:34.151 limiting how bad it is. 00:02:34.772 --> 00:02:35.533 There are, however, 00:02:35.713 --> 00:02:36.454 a whole bunch of really 00:02:36.554 --> 00:02:38.496 good things in this fee schedule. 00:02:38.596 --> 00:02:39.656 And you might remember the 00:02:40.257 --> 00:02:42.478 breaking news that we had a 00:02:42.538 --> 00:02:43.919 little bit back that 00:02:44.280 --> 00:02:45.280 predicted some of these things. 00:02:45.401 --> 00:02:47.361 And we got very lucky or 00:02:47.382 --> 00:02:48.723 just had very good advocacy. 00:02:48.742 --> 00:02:50.183 APTA had very good advocacy 00:02:50.563 --> 00:02:53.907 to get CMS to really take 00:02:53.947 --> 00:02:55.167 our side of some of these 00:02:55.568 --> 00:02:56.868 really in the weeds policy choices. 00:02:57.489 --> 00:02:58.509 And one of them I'd like to 00:02:58.550 --> 00:03:00.971 highlight actually was one 00:03:00.991 --> 00:03:02.151 I'd mentioned that may have 00:03:02.171 --> 00:03:04.592 seemed a little bit in the weeds. 00:03:05.393 --> 00:03:07.554 There are 19 codes that are 00:03:07.634 --> 00:03:10.536 often used by PTs that were 00:03:11.917 --> 00:03:13.318 impacted by the multiple 00:03:13.377 --> 00:03:14.698 procedure payment review. 00:03:15.818 --> 00:03:17.280 And basically what happened 00:03:17.360 --> 00:03:18.719 is we were successful, 00:03:18.819 --> 00:03:20.661 APTA was successful at 00:03:20.762 --> 00:03:23.062 getting CMS to recognize 00:03:23.082 --> 00:03:23.782 that these physical 00:03:23.842 --> 00:03:24.903 medicine and rehabilitation 00:03:25.484 --> 00:03:28.064 codes were misvalued. 00:03:28.544 --> 00:03:31.627 And so APTA produced a great 00:03:31.667 --> 00:03:33.127 list for these 19 codes and 00:03:33.167 --> 00:03:34.548 suggested what are known as 00:03:34.728 --> 00:03:36.389 RVUs or relative value 00:03:36.489 --> 00:03:38.669 units that are associated with the codes. 00:03:39.210 --> 00:03:41.091 And even a smaller component of that, 00:03:41.570 --> 00:03:43.292 the PE expense component of 00:03:43.331 --> 00:03:44.331 what the RVUs become. 00:03:44.372 --> 00:03:46.133 So the way it works is 00:03:46.152 --> 00:03:48.153 there's RVUs associated with each code, 00:03:48.473 --> 00:03:49.274 and then there's a couple 00:03:49.294 --> 00:03:50.294 other modifiers that 00:03:50.615 --> 00:03:51.955 that gets modified or 00:03:52.015 --> 00:03:53.538 multiplied by what's called 00:03:53.557 --> 00:03:54.778 the conversion factor. 00:03:55.299 --> 00:03:56.980 And that gives you a dollar figure, right? 00:03:57.001 --> 00:03:58.021 So the conversion factor, 00:03:58.361 --> 00:04:01.585 that 2.8% cut looks like about $32. 00:04:01.585 --> 00:04:02.686 But what's really nice is 00:04:02.725 --> 00:04:05.348 some of the inputs for 16 00:04:05.348 --> 00:04:08.151 of these 19 codes went up significantly. 00:04:08.270 --> 00:04:10.152 So even with that 2.8% cut, 00:04:11.554 --> 00:04:12.413 you're going to actually see 00:04:12.454 --> 00:04:14.094 some increases in really 00:04:14.215 --> 00:04:15.134 commonly used codes. 00:04:15.155 --> 00:04:15.876 They're not going to be big, 00:04:16.536 --> 00:04:17.255 and there were three that 00:04:17.295 --> 00:04:18.836 actually are commonly used as well, 00:04:18.857 --> 00:04:20.297 but one very commonly used 00:04:20.656 --> 00:04:22.017 that went down in value. 00:04:22.817 --> 00:04:23.637 But overall, 00:04:23.877 --> 00:04:25.959 even though there's that 2.8 percent cut, 00:04:26.358 --> 00:04:27.480 because some of the inputs 00:04:27.540 --> 00:04:28.660 and what the RVUs will 00:04:28.680 --> 00:04:29.699 become and then get 00:04:29.740 --> 00:04:31.281 multiplied by the conversion factor, 00:04:31.761 --> 00:04:33.023 you're actually going to see 00:04:33.362 --> 00:04:35.245 a couple of cents increase. 00:04:35.266 --> 00:04:36.807 That's not going to track with inflation, 00:04:37.408 --> 00:04:38.389 but it is certainly better 00:04:38.410 --> 00:04:40.773 than an almost 3% cut, which again, 00:04:40.793 --> 00:04:41.694 I'm very hopeful we'll be 00:04:41.735 --> 00:04:42.435 able to blunt through 00:04:42.475 --> 00:04:43.497 congressional advocacy. 00:04:43.536 --> 00:04:45.298 So really good news on those codes. 00:04:45.639 --> 00:04:46.300 I'm not going to go through 00:04:46.321 --> 00:04:46.901 each of them here. 00:04:47.661 --> 00:04:51.504 This chart is on page 179 of 00:04:51.545 --> 00:04:53.305 the pre-publication copy, 00:04:53.867 --> 00:04:54.867 and it looks a little 00:04:54.906 --> 00:04:55.947 misleading because it says 00:04:56.007 --> 00:04:58.529 that there's the three columns. 00:04:58.649 --> 00:05:00.891 One is the proposed RPE guidelines. 00:05:05.475 --> 00:05:06.415 Then there's the ones that 00:05:06.975 --> 00:05:07.836 the RUC produced, 00:05:07.896 --> 00:05:09.117 the Relative Value Update 00:05:09.137 --> 00:05:09.737 Committee and its 00:05:09.776 --> 00:05:11.338 subcommittee that deals 00:05:11.377 --> 00:05:13.319 with misvalued codes. 00:05:13.358 --> 00:05:14.899 And then APTA proposed ones, 00:05:15.761 --> 00:05:19.403 RVUs or PE inputs that were even higher. 00:05:19.622 --> 00:05:21.624 And CMS explicitly states in 00:05:21.663 --> 00:05:22.365 their regulation 00:05:22.665 --> 00:05:23.786 we're going to take the middle road. 00:05:24.086 --> 00:05:25.047 We're not going to go with 00:05:25.107 --> 00:05:26.468 what we had in the past. 00:05:26.788 --> 00:05:27.569 We're going to go with what 00:05:27.588 --> 00:05:28.430 the RUC suggested. 00:05:28.509 --> 00:05:31.072 And I think having the APTA 00:05:31.151 --> 00:05:32.913 suggest even higher RV use 00:05:33.673 --> 00:05:34.694 really made it easier for 00:05:34.735 --> 00:05:36.637 them to be in the middle and say, 00:05:36.937 --> 00:05:38.038 we'll go with the RUC. 00:05:38.137 --> 00:05:39.338 So you always want to be 00:05:39.778 --> 00:05:40.959 thinking in negotiation, 00:05:41.218 --> 00:05:42.300 where's the fallback for 00:05:42.360 --> 00:05:43.899 folks that probably won't 00:05:44.720 --> 00:05:46.940 automatically take the high road, 00:05:46.980 --> 00:05:47.581 as I would put it. 00:05:48.240 --> 00:05:49.161 But bottom line, 00:05:49.521 --> 00:05:50.182 what's going to happen 00:05:50.221 --> 00:05:51.242 because of those misvalued 00:05:51.281 --> 00:05:52.581 codes is many of the codes 00:05:52.622 --> 00:05:56.863 that are used by PTs will 00:05:57.004 --> 00:05:59.363 actually be paid marginally higher. 00:05:59.843 --> 00:06:00.944 Now, again, 00:06:00.964 --> 00:06:02.425 that's also why it's incredibly 00:06:02.464 --> 00:06:03.824 important to do effective 00:06:03.865 --> 00:06:05.045 congressional advocacy on 00:06:05.125 --> 00:06:05.865 blunting the cut. 00:06:06.286 --> 00:06:07.927 Because if we're able to blunt the cut, 00:06:08.247 --> 00:06:09.168 those increases will 00:06:09.187 --> 00:06:10.247 actually be even higher 00:06:10.327 --> 00:06:12.528 because the bottom line 00:06:12.569 --> 00:06:14.149 dollar figure that you get 00:06:14.209 --> 00:06:17.112 paid for each of those codes, 00:06:17.192 --> 00:06:18.031 misvalued codes, 00:06:18.411 --> 00:06:19.612 will increase if we 00:06:19.653 --> 00:06:20.934 decrease the overall 00:06:21.254 --> 00:06:22.653 payment cut that others receive. 00:06:22.714 --> 00:06:24.214 So that's really good news. 00:06:24.975 --> 00:06:26.877 It's going to be a little counterintuitive, 00:06:26.896 --> 00:06:27.117 I think, 00:06:27.137 --> 00:06:29.437 for folks to see when 2025 rolls around. 00:06:29.838 --> 00:06:31.158 And it's also not guaranteed. 00:06:31.639 --> 00:06:31.879 Right. 00:06:32.238 --> 00:06:35.100 What we need to do is in comments to CMS, 00:06:35.120 --> 00:06:36.500 because this is the draft rule, 00:06:36.560 --> 00:06:37.560 not the final rule, 00:06:37.980 --> 00:06:39.261 we need to praise them and 00:06:39.321 --> 00:06:40.401 thank them and say, 00:06:40.440 --> 00:06:41.261 you're the best ever 00:06:41.680 --> 00:06:43.021 because you implemented 00:06:43.060 --> 00:06:45.781 these misvalued codes increases. 00:06:45.922 --> 00:06:47.021 Now, we, of course, would want to say, 00:06:47.201 --> 00:06:48.442 please take the APTA ones 00:06:49.062 --> 00:06:50.283 in any future rulemaking. 00:06:50.942 --> 00:06:51.862 But overall, 00:06:51.903 --> 00:06:53.423 I would say that's a positive 00:06:53.463 --> 00:06:54.124 and it's going to be a 00:06:54.163 --> 00:06:55.363 little bit of a surprise, I think, 00:06:55.403 --> 00:06:55.783 to folks. 00:06:56.244 --> 00:06:56.985 they might actually see 00:06:57.165 --> 00:06:58.406 increases very very small 00:06:58.446 --> 00:06:59.846 but marginal increases and 00:07:00.007 --> 00:07:01.968 perhaps not decreases even 00:07:02.028 --> 00:07:03.329 with the 2.8 percent cut 00:07:03.389 --> 00:07:04.810 which again we hope to 00:07:04.850 --> 00:07:06.290 decrease so again in the 00:07:06.310 --> 00:07:07.310 weeds but I think that's 00:07:07.372 --> 00:07:09.153 really good news uh and and 00:07:09.293 --> 00:07:11.053 I just can't uh thank apta 00:07:11.074 --> 00:07:12.175 enough for the advocacy 00:07:12.214 --> 00:07:14.336 they did to make that um to 00:07:14.375 --> 00:07:16.358 make that uh uh that change 00:07:16.958 --> 00:07:18.259 um but we've got to keep it 00:07:18.338 --> 00:07:19.560 and that's why it's so 00:07:19.620 --> 00:07:21.180 important to do advocacy 00:07:22.048 --> 00:07:23.449 The KX modifier, 00:07:24.369 --> 00:07:25.189 this is one of the 00:07:25.209 --> 00:07:29.512 modifiers that is used by PTs very often. 00:07:30.252 --> 00:07:31.913 That actually increased the 00:07:31.973 --> 00:07:33.935 threshold for using that modifier, 00:07:34.014 --> 00:07:35.456 increased to $2,410 for PTs 00:07:35.475 --> 00:07:37.918 and speech language pathology services. 00:07:40.658 --> 00:07:43.461 That represents a 3.6% increase. 00:07:43.961 --> 00:07:45.101 So if you start doing a 00:07:45.141 --> 00:07:46.762 whole bunch of services for someone, 00:07:47.502 --> 00:07:48.903 that threshold when they 00:07:48.944 --> 00:07:50.485 start looking and auditing 00:07:50.925 --> 00:07:52.026 that individual's care 00:07:52.605 --> 00:07:53.846 actually has increased to 3,000, 00:07:53.846 --> 00:07:54.807 but it's sort of a gray 00:07:54.887 --> 00:07:58.389 area or a possible review after 2410. 00:07:58.389 --> 00:08:00.630 And again, that's for individuals. 00:08:00.971 --> 00:08:02.531 PT services and speech 00:08:02.572 --> 00:08:04.392 language pathology services combined. 00:08:04.853 --> 00:08:06.192 Different for occupational therapy, 00:08:06.233 --> 00:08:08.113 that's its own individual 2410. 00:08:08.113 --> 00:08:09.475 But what's great is that 00:08:09.495 --> 00:08:10.435 that's an increase of 3.6%. 00:08:10.435 --> 00:08:13.596 They recognize that costs are going up, 00:08:13.656 --> 00:08:15.336 especially for those really sick patients, 00:08:15.357 --> 00:08:15.916 the PT, 00:08:16.718 --> 00:08:18.057 or the folks who are frequent 00:08:18.098 --> 00:08:20.238 flyers with PT, who get a lot of PT, 00:08:20.278 --> 00:08:21.759 they are going to have the 00:08:21.800 --> 00:08:23.500 opportunity to receive more PT, 00:08:23.540 --> 00:08:25.281 which we of course think is 00:08:25.322 --> 00:08:27.062 a good result as a result 00:08:27.081 --> 00:08:28.362 of that threshold increase. 00:08:29.139 --> 00:08:31.004 One other thing that I think 00:08:31.064 --> 00:08:33.932 is just really great is the 00:08:34.072 --> 00:08:36.359 breakthrough on PTA general supervision. 00:08:37.178 --> 00:08:38.220 And as you may have known, 00:08:39.019 --> 00:08:40.541 PTs were really required to 00:08:40.561 --> 00:08:43.623 be on site for supervision 00:08:43.663 --> 00:08:46.846 requirements under prior CMS rules. 00:08:47.285 --> 00:08:48.447 What's really great is that 00:08:48.486 --> 00:08:49.787 CMS has recognized that 00:08:49.807 --> 00:08:50.888 they're going to be able to 00:08:50.967 --> 00:08:54.571 extend care of PTAs by 00:08:54.610 --> 00:08:58.113 having PTs be available to 00:08:58.153 --> 00:08:59.874 provide direct oversight. 00:09:00.634 --> 00:09:02.975 In the past, direct supervision, 00:09:03.657 --> 00:09:04.998 the PT had to be physically 00:09:05.158 --> 00:09:06.839 on site while services were delivered. 00:09:07.318 --> 00:09:08.320 General supervision, 00:09:08.659 --> 00:09:09.941 which is where we're going to go here, 00:09:11.282 --> 00:09:13.322 is what the new rule will 00:09:13.342 --> 00:09:14.182 be if we can keep it. 00:09:14.903 --> 00:09:15.884 That requires only that the 00:09:15.903 --> 00:09:17.625 PT be immediately accessible, 00:09:17.664 --> 00:09:18.806 but not physically in the 00:09:18.885 --> 00:09:21.248 office or patient's home with the PTA. 00:09:22.567 --> 00:09:24.328 This is a one-two punch that 00:09:24.369 --> 00:09:26.490 I'm not totally psyched about, 00:09:26.530 --> 00:09:27.311 but I think it's such an 00:09:27.350 --> 00:09:30.192 important pushback on the 00:09:30.192 --> 00:09:33.394 15 percent PTA decrease in payment. 00:09:34.495 --> 00:09:35.395 And I think this just makes 00:09:35.436 --> 00:09:37.495 sense with the focus on 00:09:37.535 --> 00:09:41.177 CMS's advocacy and health equity, right? 00:09:41.277 --> 00:09:41.937 And health equity, 00:09:42.298 --> 00:09:43.138 if you think about who 00:09:43.278 --> 00:09:45.759 receives PTA services within the country, 00:09:45.839 --> 00:09:46.658 within the real world, 00:09:47.019 --> 00:09:47.839 not just within this fee 00:09:47.859 --> 00:09:48.679 schedule craziness, 00:09:49.480 --> 00:09:50.259 it's generally folks in 00:09:50.279 --> 00:09:51.759 rural areas and underserved 00:09:51.779 --> 00:09:53.701 communities in urban areas. 00:09:53.760 --> 00:09:54.640 It's not these suburban 00:09:54.721 --> 00:09:55.922 rings where folks are 00:09:55.961 --> 00:09:57.442 really getting a lot of PTA 00:09:57.501 --> 00:09:59.643 services or services provided by PTAs. 00:10:00.182 --> 00:10:01.923 So if a PT is able to 00:10:02.144 --> 00:10:05.086 oversee multiple PTAs as 00:10:05.125 --> 00:10:06.667 opposed to having to be on site, 00:10:07.626 --> 00:10:08.447 you're going to really see 00:10:08.467 --> 00:10:09.629 some increases in access. 00:10:09.769 --> 00:10:10.749 At least that's the hope. 00:10:11.730 --> 00:10:12.990 And that's really good, right? 00:10:13.010 --> 00:10:14.130 We're going to get more PT 00:10:14.150 --> 00:10:15.331 services to more people. 00:10:15.711 --> 00:10:16.732 The thing that stinks is 00:10:16.773 --> 00:10:18.474 that that 15% decrease in 00:10:18.793 --> 00:10:20.815 PTA payments is going to 00:10:20.894 --> 00:10:23.076 impact that access. 00:10:23.115 --> 00:10:23.937 So again, 00:10:23.976 --> 00:10:25.878 I think it's sort of giving with 00:10:25.977 --> 00:10:27.278 one hand and taking away with the other. 00:10:27.759 --> 00:10:28.119 Still, 00:10:28.220 --> 00:10:29.821 with the patient focus on allowing 00:10:29.900 --> 00:10:30.782 general supervision, 00:10:31.682 --> 00:10:34.125 it's an important step forward, 00:10:34.164 --> 00:10:35.306 and we need to praise CMS 00:10:35.365 --> 00:10:36.746 for listening to us. 00:10:37.226 --> 00:10:38.488 That is also a result of 00:10:38.548 --> 00:10:44.393 this dance that Congress does with CMS. 00:10:44.813 --> 00:10:46.654 APTA and others have been 00:10:46.774 --> 00:10:47.895 very supportive of a piece 00:10:47.916 --> 00:10:50.077 of legislation that is bipartisan, 00:10:50.477 --> 00:10:51.720 looks like it was on its 00:10:51.820 --> 00:10:54.261 good way to passage, and CMS sort of beat 00:10:55.042 --> 00:10:55.903 the Congress to the punch. 00:10:55.962 --> 00:10:56.763 I still think it's important 00:10:56.783 --> 00:10:57.643 that we advocate on that 00:10:57.663 --> 00:10:59.323 legislation to sort of lock 00:10:59.464 --> 00:11:00.745 in what CMS has to do. 00:11:00.784 --> 00:11:02.085 This is really a regulation 00:11:02.144 --> 00:11:03.525 which is underneath a statute. 00:11:03.865 --> 00:11:05.147 We wanna change the statute too. 00:11:05.206 --> 00:11:07.648 So it always stays this way 00:11:07.988 --> 00:11:08.508 and that general 00:11:08.548 --> 00:11:11.188 supervision gives away or 00:11:11.330 --> 00:11:12.350 is allowed as opposed to 00:11:12.389 --> 00:11:13.591 this direct supervision structure. 00:11:14.171 --> 00:11:15.671 But this is the empower act. 00:11:15.831 --> 00:11:18.673 And I think that progress in 00:11:19.013 --> 00:11:19.913 moving that bill through 00:11:19.932 --> 00:11:20.894 the congressional process 00:11:21.374 --> 00:11:23.356 helped to justify CMS as saying, okay, 00:11:23.397 --> 00:11:25.119 yeah, we can do this on our own anyway. 00:11:25.639 --> 00:11:26.561 So why don't we go ahead and 00:11:26.620 --> 00:11:28.624 at least do it, study what it does, 00:11:28.663 --> 00:11:30.245 and then be able to provide 00:11:30.566 --> 00:11:31.366 more information on it. 00:11:31.407 --> 00:11:32.948 But good news in general 00:11:32.969 --> 00:11:34.630 supervision versus direct supervision, 00:11:35.072 --> 00:11:37.115 APTA, again, got a win there. 00:11:38.222 --> 00:11:39.964 burdensome plan of care requirements. 00:11:40.583 --> 00:11:42.565 It is so frustrating for PTs 00:11:42.725 --> 00:11:44.926 to need to provide care 00:11:45.086 --> 00:11:47.668 quickly for folks who, you know, 00:11:47.727 --> 00:11:49.207 that's the highest quality 00:11:49.248 --> 00:11:50.349 care is when it's provided 00:11:50.788 --> 00:11:51.850 quickly after an injury, 00:11:52.110 --> 00:11:53.971 or you just get the best outcomes, right? 00:11:54.010 --> 00:11:55.171 When folks are able to get 00:11:55.211 --> 00:11:56.052 into the PT quickly, 00:11:57.052 --> 00:11:58.513 And in those instances, 00:11:58.753 --> 00:11:59.852 sometimes you have to wait 00:11:59.972 --> 00:12:01.533 on the plan of care being 00:12:01.572 --> 00:12:04.214 signed off on by the referring clinician, 00:12:04.274 --> 00:12:04.474 right? 00:12:04.494 --> 00:12:05.433 Physicians, others, 00:12:05.934 --> 00:12:07.254 sometimes they sit on those documents, 00:12:07.414 --> 00:12:07.615 right? 00:12:07.674 --> 00:12:08.575 And they don't sort of 00:12:08.634 --> 00:12:10.375 prioritize signing those. 00:12:10.456 --> 00:12:12.216 And then really the PT is on the hook. 00:12:12.636 --> 00:12:13.976 They really don't have the 00:12:14.417 --> 00:12:15.716 authority to provide care 00:12:15.736 --> 00:12:17.378 until the plan of care is signed off on. 00:12:17.977 --> 00:12:20.740 That is changing under this 00:12:20.820 --> 00:12:22.681 new regulation if it becomes final. 00:12:22.801 --> 00:12:24.422 And so we have to praise CMS for this. 00:12:24.923 --> 00:12:26.504 There's a new rule on the 00:12:26.563 --> 00:12:27.745 plan of care requirements. 00:12:29.206 --> 00:12:30.466 And we're going to comment on this. 00:12:30.586 --> 00:12:32.067 But basically, 00:12:32.368 --> 00:12:34.308 the way it works is the 00:12:34.349 --> 00:12:35.129 proposal would allow the 00:12:35.149 --> 00:12:36.530 physician's signed order or 00:12:36.571 --> 00:12:37.551 referral to demonstrate 00:12:37.792 --> 00:12:39.011 initial certification of 00:12:39.032 --> 00:12:40.072 the PT's plan of care. 00:12:40.754 --> 00:12:41.813 And that's different than 00:12:41.913 --> 00:12:42.995 the way it works now, right? 00:12:43.034 --> 00:12:44.235 PTs must send their plan of 00:12:44.275 --> 00:12:45.336 care to the referring physician 00:12:45.817 --> 00:12:46.616 and secure a signature 00:12:46.657 --> 00:12:48.518 within 30 days with a PT 00:12:48.557 --> 00:12:49.239 bearing all the 00:12:49.278 --> 00:12:50.698 responsibility of getting the signature. 00:12:52.379 --> 00:12:52.659 Otherwise, 00:12:52.679 --> 00:12:53.740 the PT has to choose between 00:12:53.821 --> 00:12:55.121 stopping treatment or 00:12:55.201 --> 00:12:56.201 proceeding with the risk of 00:12:56.261 --> 00:12:57.482 not being paid by Medicare. 00:12:57.503 --> 00:12:58.822 If you can't get that signature, 00:12:59.224 --> 00:13:00.744 it's really on you whether 00:13:00.764 --> 00:13:03.005 or not that care will be reimbursed. 00:13:03.066 --> 00:13:04.645 And if you don't get the signature, 00:13:04.765 --> 00:13:05.647 it doesn't get reimbursed. 00:13:06.106 --> 00:13:08.328 So this basically provides a 00:13:08.989 --> 00:13:10.889 cushion for PTs to be able 00:13:10.929 --> 00:13:11.750 to provide that care. 00:13:11.831 --> 00:13:15.614 Again, really strong for patient results. 00:13:16.094 --> 00:13:16.313 Again, 00:13:16.354 --> 00:13:17.894 there's such good evidence to show 00:13:17.934 --> 00:13:20.017 that if folks get PT quickly, 00:13:20.356 --> 00:13:21.457 they do have better outcomes. 00:13:21.498 --> 00:13:22.918 So this is a thing that's 00:13:23.058 --> 00:13:24.139 hopefully going to decrease 00:13:24.500 --> 00:13:25.821 the risk that PTs have to 00:13:25.900 --> 00:13:27.361 take providing care to 00:13:27.402 --> 00:13:28.341 folks when the plan of care 00:13:28.381 --> 00:13:29.322 is not signed off on. 00:13:29.822 --> 00:13:31.344 I just think it's critical 00:13:31.364 --> 00:13:32.065 that that happen, 00:13:32.245 --> 00:13:34.726 and we really need to praise CMS in that. 00:13:35.506 --> 00:13:38.587 And then the final thing I'd mention is, 00:13:39.327 --> 00:13:39.788 let's see, 00:13:41.489 --> 00:13:42.349 I think I may have actually 00:13:42.469 --> 00:13:43.149 covered everything. 00:13:43.909 --> 00:13:44.149 Really, 00:13:44.190 --> 00:13:46.149 the conversion factor is going to 00:13:46.169 --> 00:13:47.311 be the main focus of our 00:13:47.350 --> 00:13:49.691 work and making sure that 00:13:49.730 --> 00:13:52.011 the conversion factor 00:13:52.052 --> 00:13:54.393 continues to be decreased. 00:13:54.552 --> 00:13:55.393 And then we'll see that 00:13:55.472 --> 00:13:58.933 increase from the misvalued 00:13:58.994 --> 00:14:00.754 codes analysis hopefully be 00:14:00.835 --> 00:14:02.514 even more effective. 00:14:02.534 --> 00:14:03.176 And so I think 2025 00:14:04.755 --> 00:14:05.936 even with these continued cuts, 00:14:06.297 --> 00:14:08.437 might be a better year than 00:14:08.437 --> 00:14:09.918 2024 in terms of Medicare payment, 00:14:10.658 --> 00:14:11.638 as well as some of the 00:14:11.738 --> 00:14:12.879 administrative burden that 00:14:12.918 --> 00:14:13.899 folks have to deal with in 00:14:13.938 --> 00:14:14.678 their practices. 00:14:14.759 --> 00:14:16.980 So again, conversion factor cut. 00:14:17.340 --> 00:14:18.059 We also have that 00:14:18.160 --> 00:14:19.600 information on the cap for 00:14:19.620 --> 00:14:20.740 the KX modifier. 00:14:21.501 --> 00:14:23.261 We're also very happy with 00:14:23.302 --> 00:14:24.442 the breakthrough on PTA 00:14:24.462 --> 00:14:25.243 general supervision. 00:14:25.763 --> 00:14:26.903 and then the plan of care 00:14:26.943 --> 00:14:28.144 requirements as well as the 00:14:28.203 --> 00:14:29.004 misvalued codes. 00:14:29.364 --> 00:14:30.404 There's a lot to be happy 00:14:30.445 --> 00:14:31.725 about in this fee schedule, 00:14:32.065 --> 00:14:33.365 but we have to lock it in 00:14:33.405 --> 00:14:34.806 and make it final and 00:14:34.907 --> 00:14:35.986 certainly not decrease the 00:14:36.067 --> 00:14:37.067 advocacy that folks are 00:14:37.086 --> 00:14:38.128 doing on Capitol Hill so 00:14:38.168 --> 00:14:39.548 effectively because that is 00:14:39.607 --> 00:14:41.448 spurring CMS to make some 00:14:41.469 --> 00:14:42.349 of these changes that they 00:14:42.389 --> 00:14:43.809 have the authority on their own to make. 00:14:44.210 --> 00:14:45.230 We need to get Congress to 00:14:45.250 --> 00:14:46.652 get out of the way and 00:14:46.831 --> 00:14:47.952 change some of those rules 00:14:47.993 --> 00:14:49.754 that CMS is locked into in 00:14:49.793 --> 00:14:50.474 terms of payment. 00:14:50.833 --> 00:14:52.576 But in the things that CMS 00:14:52.596 --> 00:14:54.636 had the authority to change 00:14:54.697 --> 00:14:56.817 on their own under the statute, 00:14:57.578 --> 00:14:58.720 I think they've done a great job. 00:14:58.879 --> 00:15:00.760 So kind of a little 00:15:00.780 --> 00:15:01.841 different than in many 00:15:01.881 --> 00:15:03.763 instances where we are even 00:15:03.802 --> 00:15:05.224 more disappointed by the fee schedule. 00:15:05.543 --> 00:15:07.304 The main thing that stinks 00:15:07.465 --> 00:15:08.365 is the payment cuts, but 00:15:08.846 --> 00:15:10.027 uh again I think I think we 00:15:10.067 --> 00:15:11.548 might see some um relief 00:15:11.609 --> 00:15:13.370 from that uh this year uh 00:15:13.570 --> 00:15:14.871 if we do our advocacy on 00:15:14.892 --> 00:15:16.972 capitol right uh and we'll 00:15:17.013 --> 00:15:18.294 hopefully be able to um to 00:15:18.335 --> 00:15:20.496 see some uh better working 00:15:20.697 --> 00:15:22.437 systems uh and more money 00:15:22.899 --> 00:15:24.419 on the table for for pts to 00:15:24.460 --> 00:15:25.961 run their practices hire 00:15:25.980 --> 00:15:28.182 new folks get more ptas uh 00:15:28.263 --> 00:15:29.644 help some of those students 00:15:29.845 --> 00:15:30.946 uh pay off their loans by 00:15:31.346 --> 00:15:32.066 offering them perhaps a 00:15:32.105 --> 00:15:33.907 little bit more and 00:15:34.167 --> 00:15:35.668 generally increasing access 00:15:36.128 --> 00:15:38.928 for PT services throughout the country. 00:15:38.969 --> 00:15:40.950 So good on you CMS for 00:15:41.629 --> 00:15:43.811 listening to all that APTA advocacy. 00:15:44.490 --> 00:15:45.410 We have to do our job in 00:15:45.451 --> 00:15:47.072 Congress and also on the 00:15:47.192 --> 00:15:48.352 regulatory comments to make 00:15:48.393 --> 00:15:49.732 sure so many of these good 00:15:49.773 --> 00:15:51.933 things remain in the final rule. 00:15:52.014 --> 00:15:54.475 So good news in many instances, 00:15:54.495 --> 00:15:55.315 but we've got to do our 00:15:55.355 --> 00:15:57.235 work to push back on how 00:15:57.296 --> 00:15:59.576 much money Congress is giving to CMS 00:16:00.456 --> 00:16:02.618 to pay for Medicare Part B's payments.