like uh intro thing looks
good to me all right once
once it's over you can
start they're about six
seconds long so we're not
too long okay all right
let's do this thing
Hi,
today I wanted to talk about a few
things that are bubbling
and this will be in lieu or
at least before we do the
series on contracting and
what might help you in your
practice to get better
rates to allow you to
provide care to your patients.
So the first thing is really
the Medicare physician fee schedule.
We talked about some of this the last time,
but the fee schedule has
come out and that was
really a preview of what
might come forward.
Luckily we have until
September 9th to comment
and there already are some
great APTA resources on commenting,
but AOPT and others will be doing,
including private practice
section will be doing comments as well,
or at least providing folks
the opportunity to focus on
value-based care for the
AOPT side and other cuts
and just payment rates generally,
as well as some coding and
other technical payer
issues or payment issues in
their comments that
individual members can send.
So the first thing is to
recognize that there is a
cut in this fee schedule.
We're really tired of these,
but it is a 2.8% cut.
And hopefully what we'll do
is we'll be able to comment to CMS,
the Centers for Medicare
and Medicaid Services,
the agency that oversees the fee schedule,
and let them know what this
will do to AOPT and other practices.
It's, like I said, about a 2.8% cut.
It's actually blunted to some extent,
but a few other things that
are in the fee schedule.
But before we get into those,
it also discusses the
Medicare Economic Index,
which would be something
that would peg the changes to inflation.
We're very supportive of that, and it
There's a solicitation for
comments on that issue.
And so tying it to inflation
makes a ton of sense,
especially with the
inflation that we've
experienced recently.
Additionally,
there's a cap on the use of
the KX modifier.
So that threshold is going to be $2,410,
and that's a 3.6% increase.
as well as for both PT and SLP services.
And then in 2024, that was 2,330.
So again,
a little bit of an increase there.
PTA supervision, it's good news here.
So as you probably know,
there is a piece of
legislation that AOPT and
others are supporting
called the Empower Act.
And really,
this is probably the reason
that CMS has made this change.
Currently,
Medicare permits general
supervision of a PT
assistant by physical
therapists in all settings.
except for outpatient
private practice under Part B,
which requires direct supervision.
We encouraged CMS through
that legislation and
through regulatory advocacy
to use their authority to
allow for the reversal of that.
And CMS listened, right?
They're proposing to change
the regulatory requirements
for OTs and PTs
who are enrolled as suppliers in Medicare,
as PTs in private practice,
to allow for general
supervision of their PT
assistants to the extent
permitted under state law.
So this is a really complicated area.
But if your state allows for
that direct supervision, sorry,
for that general supervision,
then it's likely that if
we're able to keep this in the final rule,
that will be available going forward.
So that's great news.
There's also something that
I think is going to have a
real impact on practices as well,
and that is the
certification of therapy
plans of care with a
physician or an NP order.
And so this is something that is outlined
in the REDUCE Act,
another piece of
legislation that was moving
along through Congress,
still is moving along through Congress.
And what they're proposing
is to amend the regulations
at section 424.24 , not that that matters,
but basically what it
allows for or would allow
for is a signed and dated
order or referral to be
sufficient to demonstrate
the physician NP's initial
certification of the plan of care.
So that's really good, right?
You don't have to wait then
on a plan of care that
might be sitting on a
physician's desk or in
someone's offices in order
to provide that care and
hopefully get paid for that care,
delaying the patient from
getting the care and
getting in the door as
quickly as they can.
And there are some specifics
about this that I encourage
you to read a little bit, but
Essentially,
it's a really good policy that
we want to keep in the final rule.
And again, comments are solicited on this.
There are no time
restrictions in the
regulation or specific
proposals to modify the regulation.
However,
APTA recommended that physicians
and peace have 10 business
days from their receipt,
the date of the receipt of
the plan of care to modify.
that plan of care through the REDUCE Act.
And CMS is unsure if that is
sufficient time to review
the plan of care.
So there's a few wrinkles like that one.
CMS is also soliciting
comments on whether there
should be a time limit on
the order slash referral
when it's intended to serve
as the initial certification.
We, I think,
would support a 90-day timeframe.
And that's what CMS is
requesting comments upon.
So one other thing that was
in an earlier video that I
think is important to
notice is that there is
revaluation of certain
codes that are commonly used by PTs.
And those 19 codes are in
the physical medicine and
rehabilitation code family
and really are a result of
great advocacy on the part
of APTA to get the ROC,
the Relative Value Update
Committee within the
American Medical Association
to reconsider recommended
RVUs relative value units
for these codes.
The net result is that 16 of
the 19 codes had a slight
increase in the PE expense
and three of the 19 codes
had a slight decrease in PE.
there's not that much use of
at least one of those codes
that had a decrease.
And so overall, this is really good news.
And I think we certainly
want to keep those increased valuations.
And there's actually a
proposal from APTA to make
them even higher and recommend that that
higher level of PE to the
RVU analysis be adopted.
That's what CMS said they wanted anyway,
but somehow they didn't
agree with their earlier recommendation.
And so we'd like to lock
them in or at least
encourage them to
reconsider that and make
those PE values even higher.
Some other things that folks
might really care about,
there is some lock-in on
CMS's part with telehealth,
so those flexibilities will
really only continue until
the end of the year unless Congress acts.
The problem is that that's
really expensive.
The Congressional Budget Office
has scored an extension of
that flexibility very high.
And so we're trying to look for money.
Something might happen in
the lame duck once the
election is decided.
But right now,
CMS is doing all that they
can in terms of changing or
providing that flexibility,
which is really they can't do anything.
So that's reflected in the
fee schedule as well.
We'd like to see that continue,
but I do know that
telehealth is a higher
priority for some folks than many PTs.
The quality payment program is, I think,
something that AOPT cares
very deeply about.
Others care very deeply about it as well.
But really,
with the home of the clinical
practice guidelines,
this is where we really are
able to start seeing a
linkage between good
practice and payment.
would argue that the the
quality payment program to
date for physical therapy
has been a I won't even say
it's a mitigated disaster
it's a pretty unmitigated
disaster um in terms of the
juice being worth the
squeeze and um so many pt
practices have spent a lot of money
to try to implement MIPS.
And unfortunately,
they just haven't received
any real funding back from the program.
There's certainly been some bump ups,
but I've never heard of any
practice that really made
money by scoring really high.
They may have made more in
terms of their Medicare revenue,
but the cost of setting up
the systems to be compliant
is really making
makes it really challenging to justify.
However,
there were nine new measures that
were added, and 11 were removed.
None were related to PT.
changes to the promoting
interoperability category.
There is a new MVP not starting in PT,
but ophthalmology, dermatology,
gastroenterology,
a few others are getting new MVPs.
And then two neurological
MVPs are going to be melded into one MVP.
And then there is going to
be a shift in the threshold
policies as well,
discussions of advanced
APMs and Medicare savings proposal.
And then the cost measure
scoring is going to shift too.
Finally,
probably the most important for
musculoskeletal care is the
rehabilitative support for
musculoskeletal care MVP,
which there was a comment
upon by APTA and its components.
Within this structure,
there is a proposed to
include one additional MIPS
quality score and four
qualified clinical data
registry scores or QCDR measures.
Those will include urinary incontinence,
as well as patients suffering from a neck,
upper extremity, back,
or lower extremity injury
who improve pain.
And then there's going to be
an improvement activity,
which is COVID-19 vaccine
achievement for practice staff.
There is no change in the
cost measure that was
proposed for low back pain.
And so that will continue on in this MVP.
So sadly,
I think that this is pretty much
unworkable, this MVP, for most practices,
because many of the scores
and the measures are unachievable.
And so we really want to try
to modify this as time goes
forward to make it more practicable.
Very in the weeds, but very important,
I think,
for folks to recognize that
there's at least one
continuation of the MIPS
program in terms of this
MVP MIPS value program that
will apply to PT.
It's just we have to really
continue to lobby CMS to
get them to make it
functional within the PT space.
One other thing I wanted to discuss is,
and certainly is on many
practices minds and folks who work there,
is a shift in United Health
on prior authorization.
And so in late July,
there was a publication of a notice,
really not a new policy,
showing that United was
going to implement prior
authorization for basically
all of the services that
PTs would provide after the first visit.
uh in in practices um there
are a few exceptions like
home health care um and and
in in facilities uh there
there is a there's coverage
here as well um however
there is not um a
requirement for out of
network uh folks um and so
it it's uh it's something
that's going to affect a
lot of um united healthcare
um payer uh services
Very frustrating.
APTA has been pushing back on this.
We're going to do a letter
writing campaign.
We're going to try to
continue to advocate with
United to try to at least
delay the implementation of this policy.
They gave one month for
everyone across the country
to modify their structures
to allow for this prior
authorization after the first visit.
Additionally, Optum, I would argue,
made it worse by creating an even
more complex form that
everyone will have to fill
out in order to achieve
those prior authorizations.
All of that information that's critical,
we believe is already in
the plan of care.
So it's absolutely a
paperwork burden without
any benefit to patient care.
And
Very,
very frustrating and really
unprecedented considering
that United had touted the
fact that it was moving
away from prior
authorization for physical
therapy as of last year.
This is in Medicare Advantage,
and there's been a whole bunch of
information showing that
prior authorization is
overutilized in Medicare Advantage.
So I think we have the
weight of evidence and the
weight of momentum on our
side to try to push back on this.
I think it's achievable that
we at least delay and then
hopefully rescind this policy,
just like we did with the
time in and time out shift
where we got some more
clear definitions about
what that entailed.
I'd finally say that in
terms of the fee schedule,
going back to that,
there will be opportunities
for comment for folks.
We're going to make sure
that folks can comment both
on the overall cut as well
as an opportunity to focus
on the quality measures and
the value-based care
components of the fee schedule.
So writing those comments,
there will be comments
available beyond the APTA
draft letter that folks are
going to be able to modify and use.
and just a lot happening in
august it is a sort of a
unusually busy time we are
often responding to the fee
schedule around this time
but really help folks
engage and let folks at cms
know what the perspective
is of folks in in practice
and physical therapists
really have an important
voice and it's important
with CMS and then also with the Hill.
So that's the update from DC
and the regulatory world,
as well as with UnitedHealthcare.
We'll keep you apprised of
other changes and hopefully
we'll see some successes,
just like we saw in the
initial publication of the
fee schedule in the final rule,
and then also with the
UnitedHealthcare policy.
So stay tuned,
but that's where we are right now.