WEBVTT 00:00:00.169 --> 00:00:02.271 like uh intro thing looks 00:00:02.291 --> 00:00:03.472 good to me all right once 00:00:03.754 --> 00:00:04.575 once it's over you can 00:00:04.594 --> 00:00:05.376 start they're about six 00:00:05.416 --> 00:00:06.237 seconds long so we're not 00:00:06.256 --> 00:00:07.498 too long okay all right 00:00:07.998 --> 00:00:08.599 let's do this thing 00:00:17.792 --> 00:00:18.033 Hi, 00:00:18.393 --> 00:00:19.993 today I wanted to talk about a few 00:00:20.033 --> 00:00:21.353 things that are bubbling 00:00:22.153 --> 00:00:24.234 and this will be in lieu or 00:00:24.335 --> 00:00:25.734 at least before we do the 00:00:26.995 --> 00:00:28.576 series on contracting and 00:00:28.635 --> 00:00:29.696 what might help you in your 00:00:29.716 --> 00:00:31.277 practice to get better 00:00:31.317 --> 00:00:32.356 rates to allow you to 00:00:32.417 --> 00:00:33.637 provide care to your patients. 00:00:34.457 --> 00:00:35.399 So the first thing is really 00:00:35.939 --> 00:00:37.460 the Medicare physician fee schedule. 00:00:37.500 --> 00:00:39.142 We talked about some of this the last time, 00:00:39.561 --> 00:00:40.442 but the fee schedule has 00:00:40.482 --> 00:00:41.624 come out and that was 00:00:41.664 --> 00:00:43.945 really a preview of what 00:00:43.984 --> 00:00:44.845 might come forward. 00:00:45.987 --> 00:00:46.767 Luckily we have until 00:00:46.807 --> 00:00:48.389 September 9th to comment 00:00:48.829 --> 00:00:50.149 and there already are some 00:00:50.210 --> 00:00:53.152 great APTA resources on commenting, 00:00:53.192 --> 00:00:55.433 but AOPT and others will be doing, 00:00:55.814 --> 00:00:57.174 including private practice 00:00:57.215 --> 00:00:59.036 section will be doing comments as well, 00:00:59.176 --> 00:01:00.796 or at least providing folks 00:01:00.837 --> 00:01:02.777 the opportunity to focus on 00:01:04.399 --> 00:01:06.000 value-based care for the 00:01:06.040 --> 00:01:08.501 AOPT side and other cuts 00:01:08.602 --> 00:01:09.962 and just payment rates generally, 00:01:10.283 --> 00:01:11.322 as well as some coding and 00:01:11.603 --> 00:01:13.204 other technical payer 00:01:13.245 --> 00:01:15.385 issues or payment issues in 00:01:15.926 --> 00:01:16.647 their comments that 00:01:17.186 --> 00:01:18.287 individual members can send. 00:01:18.968 --> 00:01:20.087 So the first thing is to 00:01:20.207 --> 00:01:21.448 recognize that there is a 00:01:21.489 --> 00:01:23.168 cut in this fee schedule. 00:01:23.489 --> 00:01:24.489 We're really tired of these, 00:01:25.290 --> 00:01:26.909 but it is a 2.8% cut. 00:01:27.569 --> 00:01:28.950 And hopefully what we'll do 00:01:29.070 --> 00:01:30.891 is we'll be able to comment to CMS, 00:01:31.691 --> 00:01:32.490 the Centers for Medicare 00:01:32.510 --> 00:01:33.412 and Medicaid Services, 00:01:33.492 --> 00:01:36.712 the agency that oversees the fee schedule, 00:01:36.933 --> 00:01:38.753 and let them know what this 00:01:38.772 --> 00:01:42.194 will do to AOPT and other practices. 00:01:43.254 --> 00:01:45.875 It's, like I said, about a 2.8% cut. 00:01:45.974 --> 00:01:47.656 It's actually blunted to some extent, 00:01:48.016 --> 00:01:48.996 but a few other things that 00:01:49.037 --> 00:01:50.677 are in the fee schedule. 00:01:51.558 --> 00:01:53.578 But before we get into those, 00:01:53.599 --> 00:01:54.998 it also discusses the 00:01:55.799 --> 00:01:57.060 Medicare Economic Index, 00:01:57.079 --> 00:01:57.780 which would be something 00:01:57.799 --> 00:02:01.182 that would peg the changes to inflation. 00:02:01.861 --> 00:02:03.382 We're very supportive of that, and it 00:02:06.355 --> 00:02:07.614 There's a solicitation for 00:02:07.674 --> 00:02:09.316 comments on that issue. 00:02:09.855 --> 00:02:11.516 And so tying it to inflation 00:02:11.556 --> 00:02:12.336 makes a ton of sense, 00:02:12.757 --> 00:02:13.217 especially with the 00:02:13.236 --> 00:02:13.896 inflation that we've 00:02:13.917 --> 00:02:15.098 experienced recently. 00:02:16.177 --> 00:02:16.538 Additionally, 00:02:16.557 --> 00:02:18.497 there's a cap on the use of 00:02:18.538 --> 00:02:19.778 the KX modifier. 00:02:20.459 --> 00:02:22.520 So that threshold is going to be $2,410, 00:02:22.520 --> 00:02:23.400 and that's a 3.6% increase. 00:02:28.020 --> 00:02:31.543 as well as for both PT and SLP services. 00:02:32.182 --> 00:02:32.983 And then in 2024, that was 2,330. 00:02:33.022 --> 00:02:33.223 So again, 00:02:33.243 --> 00:02:34.743 a little bit of an increase there. 00:02:39.598 --> 00:02:41.538 PTA supervision, it's good news here. 00:02:42.139 --> 00:02:44.979 So as you probably know, 00:02:45.080 --> 00:02:45.960 there is a piece of 00:02:46.020 --> 00:02:47.781 legislation that AOPT and 00:02:47.841 --> 00:02:48.760 others are supporting 00:02:49.121 --> 00:02:50.260 called the Empower Act. 00:02:51.141 --> 00:02:51.622 And really, 00:02:51.662 --> 00:02:52.921 this is probably the reason 00:02:52.961 --> 00:02:55.062 that CMS has made this change. 00:02:55.962 --> 00:02:56.383 Currently, 00:02:56.443 --> 00:02:57.462 Medicare permits general 00:02:57.483 --> 00:02:58.682 supervision of a PT 00:02:58.782 --> 00:03:00.243 assistant by physical 00:03:00.283 --> 00:03:01.383 therapists in all settings. 00:03:01.824 --> 00:03:02.625 except for outpatient 00:03:02.664 --> 00:03:04.026 private practice under Part B, 00:03:04.346 --> 00:03:06.046 which requires direct supervision. 00:03:06.987 --> 00:03:09.689 We encouraged CMS through 00:03:09.729 --> 00:03:10.650 that legislation and 00:03:10.689 --> 00:03:12.991 through regulatory advocacy 00:03:13.391 --> 00:03:15.593 to use their authority to 00:03:15.653 --> 00:03:17.875 allow for the reversal of that. 00:03:18.116 --> 00:03:20.537 And CMS listened, right? 00:03:20.556 --> 00:03:21.698 They're proposing to change 00:03:21.737 --> 00:03:22.799 the regulatory requirements 00:03:22.859 --> 00:03:23.860 for OTs and PTs 00:03:24.419 --> 00:03:26.460 who are enrolled as suppliers in Medicare, 00:03:26.520 --> 00:03:27.961 as PTs in private practice, 00:03:28.800 --> 00:03:29.681 to allow for general 00:03:29.721 --> 00:03:30.741 supervision of their PT 00:03:30.760 --> 00:03:32.181 assistants to the extent 00:03:32.222 --> 00:03:33.401 permitted under state law. 00:03:33.421 --> 00:03:35.122 So this is a really complicated area. 00:03:35.521 --> 00:03:36.802 But if your state allows for 00:03:36.842 --> 00:03:38.703 that direct supervision, sorry, 00:03:38.723 --> 00:03:39.923 for that general supervision, 00:03:40.263 --> 00:03:41.824 then it's likely that if 00:03:41.843 --> 00:03:44.264 we're able to keep this in the final rule, 00:03:44.824 --> 00:03:47.284 that will be available going forward. 00:03:48.544 --> 00:03:49.406 So that's great news. 00:03:50.265 --> 00:03:51.467 There's also something that 00:03:51.507 --> 00:03:52.207 I think is going to have a 00:03:52.247 --> 00:03:54.930 real impact on practices as well, 00:03:55.409 --> 00:03:55.950 and that is the 00:03:55.991 --> 00:03:57.252 certification of therapy 00:03:57.312 --> 00:03:58.612 plans of care with a 00:03:58.652 --> 00:04:00.334 physician or an NP order. 00:04:01.235 --> 00:04:04.356 And so this is something that is outlined 00:04:04.377 --> 00:04:05.337 in the REDUCE Act, 00:04:05.418 --> 00:04:05.957 another piece of 00:04:05.997 --> 00:04:07.139 legislation that was moving 00:04:07.199 --> 00:04:08.600 along through Congress, 00:04:08.640 --> 00:04:10.562 still is moving along through Congress. 00:04:11.342 --> 00:04:12.524 And what they're proposing 00:04:12.724 --> 00:04:14.586 is to amend the regulations 00:04:14.705 --> 00:04:19.129 at section 424.24 , not that that matters, 00:04:19.189 --> 00:04:20.230 but basically what it 00:04:20.471 --> 00:04:21.692 allows for or would allow 00:04:21.733 --> 00:04:23.293 for is a signed and dated 00:04:23.434 --> 00:04:24.956 order or referral to be 00:04:25.016 --> 00:04:26.416 sufficient to demonstrate 00:04:26.476 --> 00:04:28.038 the physician NP's initial 00:04:28.077 --> 00:04:29.480 certification of the plan of care. 00:04:30.459 --> 00:04:31.701 So that's really good, right? 00:04:31.721 --> 00:04:32.802 You don't have to wait then 00:04:33.122 --> 00:04:35.302 on a plan of care that 00:04:35.322 --> 00:04:35.983 might be sitting on a 00:04:36.004 --> 00:04:37.024 physician's desk or in 00:04:37.064 --> 00:04:39.386 someone's offices in order 00:04:39.425 --> 00:04:41.887 to provide that care and 00:04:42.627 --> 00:04:43.968 hopefully get paid for that care, 00:04:45.290 --> 00:04:46.430 delaying the patient from 00:04:46.449 --> 00:04:47.190 getting the care and 00:04:47.411 --> 00:04:48.050 getting in the door as 00:04:48.091 --> 00:04:48.992 quickly as they can. 00:04:50.173 --> 00:04:51.934 And there are some specifics 00:04:51.994 --> 00:04:52.874 about this that I encourage 00:04:52.894 --> 00:04:53.814 you to read a little bit, but 00:04:55.076 --> 00:04:55.495 Essentially, 00:04:55.536 --> 00:04:57.598 it's a really good policy that 00:04:57.637 --> 00:04:59.660 we want to keep in the final rule. 00:05:00.341 --> 00:05:02.101 And again, comments are solicited on this. 00:05:03.163 --> 00:05:04.043 There are no time 00:05:04.103 --> 00:05:04.644 restrictions in the 00:05:04.685 --> 00:05:05.865 regulation or specific 00:05:05.906 --> 00:05:07.567 proposals to modify the regulation. 00:05:08.247 --> 00:05:08.567 However, 00:05:08.627 --> 00:05:10.069 APTA recommended that physicians 00:05:10.129 --> 00:05:11.089 and peace have 10 business 00:05:11.110 --> 00:05:11.831 days from their receipt, 00:05:12.651 --> 00:05:13.892 the date of the receipt of 00:05:13.913 --> 00:05:14.973 the plan of care to modify. 00:05:15.194 --> 00:05:16.694 that plan of care through the REDUCE Act. 00:05:17.776 --> 00:05:18.956 And CMS is unsure if that is 00:05:18.995 --> 00:05:19.997 sufficient time to review 00:05:20.036 --> 00:05:20.716 the plan of care. 00:05:20.817 --> 00:05:23.718 So there's a few wrinkles like that one. 00:05:24.699 --> 00:05:25.880 CMS is also soliciting 00:05:25.920 --> 00:05:26.901 comments on whether there 00:05:26.920 --> 00:05:28.062 should be a time limit on 00:05:28.101 --> 00:05:29.163 the order slash referral 00:05:29.182 --> 00:05:30.202 when it's intended to serve 00:05:30.242 --> 00:05:31.303 as the initial certification. 00:05:32.463 --> 00:05:33.365 We, I think, 00:05:33.384 --> 00:05:35.105 would support a 90-day timeframe. 00:05:36.086 --> 00:05:36.987 And that's what CMS is 00:05:37.286 --> 00:05:39.348 requesting comments upon. 00:05:40.329 --> 00:05:41.589 So one other thing that was 00:05:41.649 --> 00:05:43.550 in an earlier video that I 00:05:43.591 --> 00:05:44.511 think is important to 00:05:44.571 --> 00:05:46.230 notice is that there is 00:05:46.290 --> 00:05:47.471 revaluation of certain 00:05:47.531 --> 00:05:50.232 codes that are commonly used by PTs. 00:05:50.971 --> 00:05:52.351 And those 19 codes are in 00:05:52.391 --> 00:05:53.312 the physical medicine and 00:05:53.333 --> 00:05:54.673 rehabilitation code family 00:05:55.673 --> 00:05:56.952 and really are a result of 00:05:57.353 --> 00:05:58.593 great advocacy on the part 00:05:58.613 --> 00:06:00.593 of APTA to get the ROC, 00:06:00.673 --> 00:06:02.033 the Relative Value Update 00:06:02.074 --> 00:06:03.175 Committee within the 00:06:03.214 --> 00:06:04.375 American Medical Association 00:06:04.875 --> 00:06:07.757 to reconsider recommended 00:06:07.858 --> 00:06:09.721 RVUs relative value units 00:06:09.821 --> 00:06:11.642 for these codes. 00:06:12.043 --> 00:06:14.206 The net result is that 16 of 00:06:14.245 --> 00:06:15.447 the 19 codes had a slight 00:06:15.547 --> 00:06:18.230 increase in the PE expense 00:06:18.610 --> 00:06:19.451 and three of the 19 codes 00:06:19.471 --> 00:06:20.673 had a slight decrease in PE. 00:06:21.394 --> 00:06:22.634 there's not that much use of 00:06:22.735 --> 00:06:23.757 at least one of those codes 00:06:23.797 --> 00:06:24.617 that had a decrease. 00:06:25.237 --> 00:06:27.079 And so overall, this is really good news. 00:06:27.160 --> 00:06:29.002 And I think we certainly 00:06:29.041 --> 00:06:31.704 want to keep those increased valuations. 00:06:31.745 --> 00:06:32.346 And there's actually a 00:06:32.386 --> 00:06:34.327 proposal from APTA to make 00:06:34.348 --> 00:06:37.271 them even higher and recommend that that 00:06:38.271 --> 00:06:42.074 higher level of PE to the 00:06:42.214 --> 00:06:44.516 RVU analysis be adopted. 00:06:44.975 --> 00:06:46.716 That's what CMS said they wanted anyway, 00:06:46.776 --> 00:06:47.577 but somehow they didn't 00:06:47.978 --> 00:06:49.519 agree with their earlier recommendation. 00:06:49.918 --> 00:06:50.800 And so we'd like to lock 00:06:50.839 --> 00:06:51.579 them in or at least 00:06:51.661 --> 00:06:52.800 encourage them to 00:06:52.901 --> 00:06:53.982 reconsider that and make 00:06:54.002 --> 00:06:56.923 those PE values even higher. 00:06:58.322 --> 00:06:59.483 Some other things that folks 00:06:59.523 --> 00:07:00.343 might really care about, 00:07:00.564 --> 00:07:02.584 there is some lock-in on 00:07:02.624 --> 00:07:04.425 CMS's part with telehealth, 00:07:04.504 --> 00:07:06.406 so those flexibilities will 00:07:06.446 --> 00:07:07.625 really only continue until 00:07:07.665 --> 00:07:09.586 the end of the year unless Congress acts. 00:07:10.026 --> 00:07:11.807 The problem is that that's 00:07:11.846 --> 00:07:12.687 really expensive. 00:07:13.048 --> 00:07:14.208 The Congressional Budget Office 00:07:14.608 --> 00:07:16.668 has scored an extension of 00:07:16.709 --> 00:07:19.009 that flexibility very high. 00:07:19.449 --> 00:07:21.511 And so we're trying to look for money. 00:07:22.331 --> 00:07:23.112 Something might happen in 00:07:23.151 --> 00:07:24.492 the lame duck once the 00:07:24.512 --> 00:07:25.392 election is decided. 00:07:25.992 --> 00:07:26.632 But right now, 00:07:27.334 --> 00:07:28.434 CMS is doing all that they 00:07:28.473 --> 00:07:31.035 can in terms of changing or 00:07:31.074 --> 00:07:32.055 providing that flexibility, 00:07:32.076 --> 00:07:33.235 which is really they can't do anything. 00:07:33.875 --> 00:07:34.757 So that's reflected in the 00:07:34.776 --> 00:07:35.637 fee schedule as well. 00:07:35.916 --> 00:07:37.057 We'd like to see that continue, 00:07:37.098 --> 00:07:37.718 but I do know that 00:07:37.737 --> 00:07:39.019 telehealth is a higher 00:07:39.038 --> 00:07:41.279 priority for some folks than many PTs. 00:07:42.235 --> 00:07:43.697 The quality payment program is, I think, 00:07:43.757 --> 00:07:45.858 something that AOPT cares 00:07:45.899 --> 00:07:46.699 very deeply about. 00:07:47.100 --> 00:07:48.701 Others care very deeply about it as well. 00:07:49.362 --> 00:07:49.822 But really, 00:07:50.341 --> 00:07:52.483 with the home of the clinical 00:07:52.504 --> 00:07:53.384 practice guidelines, 00:07:54.425 --> 00:07:55.485 this is where we really are 00:07:55.545 --> 00:07:56.567 able to start seeing a 00:07:57.148 --> 00:07:58.629 linkage between good 00:07:58.668 --> 00:07:59.670 practice and payment. 00:08:01.490 --> 00:08:02.673 would argue that the the 00:08:02.733 --> 00:08:03.834 quality payment program to 00:08:03.874 --> 00:08:05.156 date for physical therapy 00:08:05.196 --> 00:08:06.999 has been a I won't even say 00:08:07.038 --> 00:08:08.420 it's a mitigated disaster 00:08:08.440 --> 00:08:09.581 it's a pretty unmitigated 00:08:09.622 --> 00:08:11.305 disaster um in terms of the 00:08:11.345 --> 00:08:12.045 juice being worth the 00:08:12.105 --> 00:08:14.548 squeeze and um so many pt 00:08:14.589 --> 00:08:16.711 practices have spent a lot of money 00:08:17.233 --> 00:08:18.653 to try to implement MIPS. 00:08:19.754 --> 00:08:20.735 And unfortunately, 00:08:20.776 --> 00:08:21.815 they just haven't received 00:08:21.896 --> 00:08:25.619 any real funding back from the program. 00:08:25.639 --> 00:08:26.959 There's certainly been some bump ups, 00:08:27.019 --> 00:08:28.300 but I've never heard of any 00:08:28.341 --> 00:08:30.922 practice that really made 00:08:30.983 --> 00:08:32.744 money by scoring really high. 00:08:33.384 --> 00:08:34.144 They may have made more in 00:08:34.184 --> 00:08:35.225 terms of their Medicare revenue, 00:08:35.245 --> 00:08:36.586 but the cost of setting up 00:08:36.625 --> 00:08:38.748 the systems to be compliant 00:08:38.947 --> 00:08:40.349 is really making 00:08:40.469 --> 00:08:43.876 makes it really challenging to justify. 00:08:43.897 --> 00:08:45.541 However, 00:08:45.581 --> 00:08:47.144 there were nine new measures that 00:08:47.186 --> 00:08:49.149 were added, and 11 were removed. 00:08:49.211 --> 00:08:50.153 None were related to PT. 00:08:52.636 --> 00:08:53.576 changes to the promoting 00:08:53.616 --> 00:08:54.937 interoperability category. 00:08:55.999 --> 00:09:00.821 There is a new MVP not starting in PT, 00:09:00.900 --> 00:09:02.682 but ophthalmology, dermatology, 00:09:02.721 --> 00:09:03.402 gastroenterology, 00:09:03.442 --> 00:09:06.202 a few others are getting new MVPs. 00:09:06.842 --> 00:09:08.224 And then two neurological 00:09:08.244 --> 00:09:10.965 MVPs are going to be melded into one MVP. 00:09:11.985 --> 00:09:13.385 And then there is going to 00:09:13.405 --> 00:09:14.606 be a shift in the threshold 00:09:14.687 --> 00:09:16.427 policies as well, 00:09:16.509 --> 00:09:17.889 discussions of advanced 00:09:17.950 --> 00:09:20.672 APMs and Medicare savings proposal. 00:09:21.312 --> 00:09:22.192 And then the cost measure 00:09:22.232 --> 00:09:23.474 scoring is going to shift too. 00:09:25.635 --> 00:09:25.996 Finally, 00:09:26.057 --> 00:09:27.677 probably the most important for 00:09:28.479 --> 00:09:30.760 musculoskeletal care is the 00:09:30.900 --> 00:09:32.322 rehabilitative support for 00:09:32.962 --> 00:09:34.764 musculoskeletal care MVP, 00:09:35.465 --> 00:09:37.265 which there was a comment 00:09:37.306 --> 00:09:40.168 upon by APTA and its components. 00:09:41.529 --> 00:09:42.711 Within this structure, 00:09:42.750 --> 00:09:43.791 there is a proposed to 00:09:43.831 --> 00:09:44.991 include one additional MIPS 00:09:45.052 --> 00:09:46.933 quality score and four 00:09:47.134 --> 00:09:48.174 qualified clinical data 00:09:48.195 --> 00:09:50.035 registry scores or QCDR measures. 00:09:51.177 --> 00:09:52.898 Those will include urinary incontinence, 00:09:53.057 --> 00:09:54.860 as well as patients suffering from a neck, 00:09:55.299 --> 00:09:56.441 upper extremity, back, 00:09:56.541 --> 00:09:57.761 or lower extremity injury 00:09:57.802 --> 00:09:58.761 who improve pain. 00:09:59.602 --> 00:10:00.163 And then there's going to be 00:10:00.182 --> 00:10:01.043 an improvement activity, 00:10:01.924 --> 00:10:04.807 which is COVID-19 vaccine 00:10:04.826 --> 00:10:06.087 achievement for practice staff. 00:10:06.467 --> 00:10:07.828 There is no change in the 00:10:07.889 --> 00:10:08.809 cost measure that was 00:10:08.870 --> 00:10:11.491 proposed for low back pain. 00:10:11.951 --> 00:10:15.134 And so that will continue on in this MVP. 00:10:15.193 --> 00:10:16.975 So sadly, 00:10:16.995 --> 00:10:19.937 I think that this is pretty much 00:10:20.038 --> 00:10:22.179 unworkable, this MVP, for most practices, 00:10:22.580 --> 00:10:24.181 because many of the scores 00:10:24.240 --> 00:10:26.722 and the measures are unachievable. 00:10:27.504 --> 00:10:28.764 And so we really want to try 00:10:28.803 --> 00:10:30.505 to modify this as time goes 00:10:30.546 --> 00:10:32.047 forward to make it more practicable. 00:10:32.687 --> 00:10:34.568 Very in the weeds, but very important, 00:10:34.649 --> 00:10:34.869 I think, 00:10:34.889 --> 00:10:36.671 for folks to recognize that 00:10:36.691 --> 00:10:37.591 there's at least one 00:10:39.153 --> 00:10:40.313 continuation of the MIPS 00:10:40.354 --> 00:10:41.934 program in terms of this 00:10:42.035 --> 00:10:46.278 MVP MIPS value program that 00:10:46.318 --> 00:10:47.419 will apply to PT. 00:10:47.519 --> 00:10:48.480 It's just we have to really 00:10:48.561 --> 00:10:51.764 continue to lobby CMS to 00:10:51.783 --> 00:10:52.524 get them to make it 00:10:52.664 --> 00:10:54.907 functional within the PT space. 00:10:56.317 --> 00:10:58.062 One other thing I wanted to discuss is, 00:10:58.604 --> 00:11:00.048 and certainly is on many 00:11:00.067 --> 00:11:02.014 practices minds and folks who work there, 00:11:02.576 --> 00:11:04.240 is a shift in United Health 00:11:07.678 --> 00:11:09.260 on prior authorization. 00:11:10.182 --> 00:11:11.744 And so in late July, 00:11:12.303 --> 00:11:14.807 there was a publication of a notice, 00:11:15.206 --> 00:11:16.448 really not a new policy, 00:11:17.429 --> 00:11:18.610 showing that United was 00:11:18.650 --> 00:11:19.873 going to implement prior 00:11:19.893 --> 00:11:22.195 authorization for basically 00:11:22.355 --> 00:11:23.756 all of the services that 00:11:23.797 --> 00:11:26.860 PTs would provide after the first visit. 00:11:27.581 --> 00:11:30.101 uh in in practices um there 00:11:30.201 --> 00:11:31.361 are a few exceptions like 00:11:31.422 --> 00:11:33.383 home health care um and and 00:11:33.442 --> 00:11:34.883 in in facilities uh there 00:11:34.984 --> 00:11:35.943 there is a there's coverage 00:11:35.964 --> 00:11:37.364 here as well um however 00:11:37.403 --> 00:11:38.384 there is not um a 00:11:38.424 --> 00:11:39.225 requirement for out of 00:11:39.284 --> 00:11:41.586 network uh folks um and so 00:11:41.605 --> 00:11:42.966 it it's uh it's something 00:11:42.985 --> 00:11:43.785 that's going to affect a 00:11:43.846 --> 00:11:45.907 lot of um united healthcare 00:11:45.927 --> 00:11:48.388 um payer uh services 00:11:49.427 --> 00:11:50.188 Very frustrating. 00:11:50.448 --> 00:11:52.671 APTA has been pushing back on this. 00:11:53.051 --> 00:11:54.072 We're going to do a letter 00:11:54.111 --> 00:11:54.851 writing campaign. 00:11:54.871 --> 00:11:56.273 We're going to try to 00:11:56.332 --> 00:11:58.274 continue to advocate with 00:11:58.815 --> 00:12:00.456 United to try to at least 00:12:00.576 --> 00:12:02.317 delay the implementation of this policy. 00:12:02.336 --> 00:12:04.119 They gave one month for 00:12:04.239 --> 00:12:05.500 everyone across the country 00:12:05.539 --> 00:12:07.620 to modify their structures 00:12:07.681 --> 00:12:10.163 to allow for this prior 00:12:10.182 --> 00:12:11.744 authorization after the first visit. 00:12:12.504 --> 00:12:13.826 Additionally, Optum, I would argue, 00:12:13.846 --> 00:12:15.626 made it worse by creating an even 00:12:16.086 --> 00:12:18.669 more complex form that 00:12:18.710 --> 00:12:19.530 everyone will have to fill 00:12:19.610 --> 00:12:21.293 out in order to achieve 00:12:21.332 --> 00:12:22.433 those prior authorizations. 00:12:23.115 --> 00:12:24.537 All of that information that's critical, 00:12:24.596 --> 00:12:25.457 we believe is already in 00:12:25.498 --> 00:12:26.178 the plan of care. 00:12:26.259 --> 00:12:27.360 So it's absolutely a 00:12:27.399 --> 00:12:28.421 paperwork burden without 00:12:28.461 --> 00:12:30.123 any benefit to patient care. 00:12:30.764 --> 00:12:30.964 And 00:12:31.384 --> 00:12:31.605 Very, 00:12:31.644 --> 00:12:33.807 very frustrating and really 00:12:33.966 --> 00:12:35.148 unprecedented considering 00:12:35.187 --> 00:12:37.070 that United had touted the 00:12:37.090 --> 00:12:37.931 fact that it was moving 00:12:37.971 --> 00:12:39.633 away from prior 00:12:39.653 --> 00:12:40.653 authorization for physical 00:12:40.673 --> 00:12:42.096 therapy as of last year. 00:12:42.676 --> 00:12:44.457 This is in Medicare Advantage, 00:12:44.577 --> 00:12:45.879 and there's been a whole bunch of 00:12:46.399 --> 00:12:47.341 information showing that 00:12:47.360 --> 00:12:48.120 prior authorization is 00:12:48.201 --> 00:12:49.701 overutilized in Medicare Advantage. 00:12:49.761 --> 00:12:52.482 So I think we have the 00:12:52.523 --> 00:12:53.802 weight of evidence and the 00:12:53.844 --> 00:12:56.245 weight of momentum on our 00:12:56.284 --> 00:12:57.504 side to try to push back on this. 00:12:57.585 --> 00:12:59.066 I think it's achievable that 00:12:59.105 --> 00:13:00.086 we at least delay and then 00:13:00.125 --> 00:13:01.927 hopefully rescind this policy, 00:13:02.287 --> 00:13:03.148 just like we did with the 00:13:03.207 --> 00:13:04.889 time in and time out shift 00:13:05.149 --> 00:13:07.669 where we got some more 00:13:07.750 --> 00:13:08.710 clear definitions about 00:13:08.750 --> 00:13:09.510 what that entailed. 00:13:10.591 --> 00:13:11.711 I'd finally say that in 00:13:11.751 --> 00:13:12.712 terms of the fee schedule, 00:13:12.753 --> 00:13:13.493 going back to that, 00:13:13.552 --> 00:13:14.874 there will be opportunities 00:13:14.913 --> 00:13:15.955 for comment for folks. 00:13:15.975 --> 00:13:17.155 We're going to make sure 00:13:17.196 --> 00:13:19.878 that folks can comment both 00:13:20.097 --> 00:13:23.080 on the overall cut as well 00:13:23.279 --> 00:13:25.120 as an opportunity to focus 00:13:25.321 --> 00:13:26.902 on the quality measures and 00:13:27.261 --> 00:13:28.523 the value-based care 00:13:28.582 --> 00:13:30.845 components of the fee schedule. 00:13:30.865 --> 00:13:32.666 So writing those comments, 00:13:33.186 --> 00:13:33.986 there will be comments 00:13:34.287 --> 00:13:35.807 available beyond the APTA 00:13:36.489 --> 00:13:37.870 draft letter that folks are 00:13:37.889 --> 00:13:39.350 going to be able to modify and use. 00:13:40.150 --> 00:13:41.051 and just a lot happening in 00:13:41.150 --> 00:13:43.231 august it is a sort of a 00:13:43.552 --> 00:13:45.832 unusually busy time we are 00:13:45.873 --> 00:13:46.832 often responding to the fee 00:13:46.852 --> 00:13:47.832 schedule around this time 00:13:47.873 --> 00:13:49.033 but really help folks 00:13:49.073 --> 00:13:51.293 engage and let folks at cms 00:13:51.313 --> 00:13:53.815 know what the perspective 00:13:53.955 --> 00:13:56.515 is of folks in in practice 00:13:56.535 --> 00:13:57.716 and physical therapists 00:13:58.755 --> 00:13:59.657 really have an important 00:13:59.697 --> 00:14:00.976 voice and it's important 00:14:06.317 --> 00:14:08.078 with CMS and then also with the Hill. 00:14:08.658 --> 00:14:10.879 So that's the update from DC 00:14:10.960 --> 00:14:12.301 and the regulatory world, 00:14:13.061 --> 00:14:14.501 as well as with UnitedHealthcare. 00:14:14.782 --> 00:14:15.761 We'll keep you apprised of 00:14:16.101 --> 00:14:17.263 other changes and hopefully 00:14:17.302 --> 00:14:18.302 we'll see some successes, 00:14:18.682 --> 00:14:20.264 just like we saw in the 00:14:20.323 --> 00:14:21.384 initial publication of the 00:14:21.423 --> 00:14:23.225 fee schedule in the final rule, 00:14:23.345 --> 00:14:25.846 and then also with the 00:14:26.265 --> 00:14:27.267 UnitedHealthcare policy. 00:14:27.326 --> 00:14:28.586 So stay tuned, 00:14:28.947 --> 00:14:30.048 but that's where we are right now.