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Medical Rehab

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The Centers for Medicare and Medicaid Services (CMS) issued the calendar year (CY) 2017 Medicare Physician Fee Schedule Proposed Rule, which was published in the July 15, 2016 Federal Register. Some of the key provisions proposed include:

New Physical Therapy and Occupational Therapy Codes

CMS is proposing new CPT codes for physical therapy and occupational therapy evaluative procedures. The new codes are listed on Page 350 of the proposed rule in table 19 and include: 97X61, 97X62, 97X63, 97X64, 97X65, 97X66, 97X67, and 97X68. These codes are deemed “always therapy” regardless of the type of provider who bills for the service, and thus are subject to the statutory therapy caps.

Misvalued Therapy Codes

As part of the continued misvalued code initiative, CMS identifies ten potential therapy codes that fall under the “codes that account for the majority of spending under the physician fee schedule” statutory category. The ten codes that CMS requests comment on include the following: 97032 electrical stimulation; 97035 ultrasound therapy; 97110 therapeutic exercises; 97112 neuromuscular reeducation; 97113 aquatic therapy/exercises; 97116 gait training therapy; 97140 manual therapy 1/regions; 97530 therapeutic activities; 97535 self-care management training; and G0283 electrical stimulation other than wound.

Physician Value-based Modifier

The Value-based Payment Modifier (VM) provides for differential payments under the PFS to self-employed physicians, groups of physicians, and other eligible professionals (EPs) based on the quality and cost of care they furnish to beneficiaries enrolled in the traditional Medicare Fee-for-Service (FFS) program. Under the VM Program, performance on quality and cost measures can translate into payment incentives for EPs who provide high quality, efficient care, while EPs who underperform may be subject to a downward adjustment. This program is set to expire on January 1, 2019, as a new comprehensive program required by the Medicare Access and CHIP Reauthorization Act, called the Merit-based Incentive Program, begins in CY 2019. For CY 2017, CMS requests feedback on four scenarios that aim to help physician groups and solo practitioners better predict the outcome of their final VM adjustment and to minimize claims reprocessing.

Medicare Shared Savings Program

Within the Medicare Shared Savings Program, CMS proposes to introduce beneficiary protections related to the use of the skilled nursing facility (SNF) 3-Day Waiver, currently limited to beneficiaries in a Track 3 Accountable Care Organization (ACO). CMS estimates the first SNF 3-day rule waiver applications from Track 3 ACOs to be accepted later this summer. The following additional beneficiary protections are proposed in order to ensure proper use of the SNF 3-day rule waiver:

  • Establishment of a 90-day grace period that would permit payment for SNF services provided to beneficiaries who were initially on an ACO’s prospective assignment list for a performance year, but subsequently excluded during the performance year;
  • Requirement that a beneficiary who was never prospectively assigned to a waiver-approved ACO is not subject to non-covered SNF services; and
  • Misuse of a waiver may result in CMS taking remedial action against an ACO. CMS has indicated they will develop a process for ACOs to confirm that they have met all the SNF 3-day rule waiver requirements and requests comments on the proposed beneficiary protection policies.

Medicare Advantage Provider Enrollment

CMS proposes to require Medicare Advantage (MA) organization providers and suppliers to also be enrolled in Medicare in an approved status. The statutory definition of a “provider of services” includes a hospital, critical access hospital, SNF, a comprehensive outpatient rehabilitation facility, a home health agency, or a hospice. According to CMS, this requirement is needed to ensure that MA enrollees receive appropriate or medically necessary items or services from health care providers and suppliers that fully comply with Medicare enrollment requirements and have not had their privileges revoked. The Medicare enrollment requirement would be part of CMS contracts with MA plans, and those failing to meet this requirement could be subject to contract actions ranging from sanctions to termination. This proposal would create consistency with the provider and supplier enrollment requirements for all other Parts of Medicare (i.e., Medicare Part A, Part B, and Part D), and would also parallel requirements for providers participating in Medicaid managed care organizations.

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The Centers for Medicare and Medicaid Services (CMS) will be hosting a two-day, in-person training event on Tuesday, August 9 and Wednesday, August 10, 2016 on the Inpatient Rehabilitation Facility (IRF) Quality Reporting Program (QRP) in Chicago, IL. This event will also be accessible via streaming media (registration is not required to participate via webcast). The event is scheduled to begin at 9:00 am EDT both days. This training is for IRF providers, associations, and organizations. The objective is to provide IRFs with assessment-based data collection instructions and updates associated with the changes in the October 1, 2016, release of the IRF-Patient Assessment Instrument V 1.4 and other reporting requirements of the IRF QRP. IRF preview reports and IRF Compare will also be discussed.

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The Centers for Medicare and Medicaid Services (CMS) published the proposed hospital outpatient prospective payment system (OPPS) payment rule for calendar year (CY) 2017 in the July 14, 2016 Federal Register. A key proposal in the rule is to implement Section 603 of the Bipartisan Budget Act of 2015 (also known as the Site Neutral Payments Provision), which provides that certain hospital off-campus outpatient departments would no longer be paid under OPPS. Currently, Medicare pays for the same services at a higher rate if those services are provided in a hospital outpatient department, rather than a physician’s office. This payment differential has encouraged hospitals to acquire physician offices in order to receive the higher rates. This acquisition trend and difference in payment has been highlighted as a long-standing issue of concern by congress, the Medicare Payment Advisory Commission, and the Department of Health and Human Services Office of Inspector General.

In addition, based on concerns raised by health care providers on the patient experience survey questions about pain management, CMS is proposing to remove the pain management dimension of the Hospital Consumer Assessment of Healthcare Providers and Systems survey, for purposes of the Hospital Value Based Purchasing Program. The goal is to eliminate any potential financial pressure clinicians may feel to overprescribe pain medications.

CMS has also included a provision to increase flexibility for hospitals that participate in the Medicare electronic health records (EHR) incentive program. Earlier this year, CMS conducted a review of the Medicare EHR Incentive Program for clinicians as part of the implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), with the aim of reconsidering the program so we move closer to achieving the full potential that health information technology offers. Based on that review, CMS streamlined EHR reporting requirements under the proposed rule to implement certain provisions of MACRA, to increase flexibility and support improved patient outcomes. CMS is proposing to take a similar step for hospitals participating in the Medicare EHR Incentive Program. These changes include a proposal for clinicians, hospitals, and critical access hospitals to use a 90-day EHR reporting period in 2016 (down from a full calendar year for returning participants). This increases flexibility and lowers the reporting burden for hospital providers.

Finally, CMS proposes to add new quality measures to the Hospital Outpatient Quality Reporting Program that are focused on improving patient outcomes and experience of care. Other changes in the proposed rule would enhance the outcome requirements for organ transplant programs, so that the programs may help more beneficiaries accept more grafts, while maintaining compliance with Medicare standards for patient and graft survival.

CMS estimates that the updates in the proposed rule would increase OPPS payments by 1.6 percent. Comments on the proposed rule will be accepted through Tuesday, September 6, 2016.

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In an effort to reduce the large backlog of Medicare coverage and payment appeals, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule that would revise the procedures the Department of Health and Human Services (HHS) would follow at the Administrative Law Judge (ALJ) level for appeals of payment and coverage determinations. This proposed rule covers items and services provided to Medicare beneficiaries, enrollees in Medicare Advantage and other Medicare competitive health plans, and enrollees in Medicare prescription drug plans, as well as appeals of Medicare beneficiary enrollment and entitlement determinations, and certain Medicare premium appeals. In addition, the proposed rule would revise procedures that HHS would follow at CMS and the Medicare Appeals Council levels of appeal for certain matters affecting the ALJ level. As of April 2016, the Office of Medicare Hearings and Appeals (OMHA) had over 750,000 pending appeals, while OMHA’s adjudication capacity was 77,000 appeals per year, with an additional adjudication capacity of 15,000 appeals per year expected by the end of the current fiscal year. The proposed rule includes provisions to expand the pool of available OMHA adjudicators and improve the efficiency of the appeals process by streamlining the processes so less time is spent by adjudicators and parties on repetitive issues and procedural matters. The proposed rule was published in the July 5, 2016 Federal Register. Comments are due by Monday, August 29, 2016.

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The Office of Vocational Rehabilitation (OVR) is conducting a comprehensive statewide needs assessment designed to meet and satisfy the state plan requirements in the Rehabilitation Act of 1973, as amended, and the Workforce Innovation and Opportunity Act. As part of this assessment, the Institute on Disabilities at Temple University is asking Pennsylvania employers and workforce professionals to complete a brief survey to identify how OVR can better support employers and employees across Pennsylvania.

This project is being conducted in cooperation with the Pennsylvania Rehabilitation Council and with the assistance of the Institute on Disabilities. If you are an employer or a workforce professional you are encouraged to complete this brief survey by Monday, August 1. Once you’ve completed the survey, you can enter in a drawing to win a $20 Target gift card.

The Institute on Disabilities is also seeking employer stakeholders to participate in brief phone interviews and share their expertise with the Institute. Interested employers can email or call 215-204-9544.

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Your feedback is greatly needed. The US Department of Labor (DOL) has issued its final overtime rule which increases the threshold related to the overtime exemption. This has caused great concern among RCPA members as there is no additional funding being proposed to cover the cost of this change. RCPA will be submitting testimony and testifying in front of the Senate Labor and Industry and Senate Appropriations Committees on Tuesday, June 21 regarding this issue. In preparation for this important Senate hearing, we are asking members to complete this SURVEY no later than Wednesday, June 15, so that we have data to present in addition to our concerns.

If you have already taken the survey, you do not need to provide feedback again. We appreciate your attention and input regarding this very important issue. Thank you.

Please contact RCPA Director of Government Affairs Jack Phillips with any questions.

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The Department of Human Services (DHS) just announced their decision to lengthen the transition time for the start of the Community HealthChoices (CHC) program. The first phase (southwest part of the state) was originally scheduled to be implemented on January 1, 2017. The implementation date of phase one has now been changed to begin July 1, 2017.

The decision to extend the start date allows more time for the 420,000 Pennsylvanians who will ultimately benefit from CHC to understand the program adjustments that will occur, including how access to and receipt of home- and community-based services will be improved.

All other established CHC timeframes will remain the same. The selection of managed care companies, changes in the Commonwealth’s information technology systems, and other changes are still proceeding on the same timeframe. The implementation of phases two and three (the southeast and remainder of the Commonwealth) also remain on the previously announced timelines of 2018 and 2019, respectively.

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The commencement of Certified Community Behavioral Health Clinics through Pennsylvania’s Department of Human Services, and the growing movement of individual providers to create medical homes to provide clients with co-located mental health and primary care providers in one facility, holds tremendous promise and opportunity for the coordination and enhancement of delivery of care to clients. These new provider relationships in shared office and facility spaces create new legal issues for providers under the federal Stark law and Anti-kickback statute. Providers must ensure that they do not inadvertently run afoul of these important federal fraud and abuse laws.

RCPA will offer a webinar presented by Renee H. Martin, JD, RN, MSN, a partner in the firm of Dilworth Paxson, LLP. This webinar will describe the legal requirements providers must be aware of under these federal laws and help to apply that knowledge in structuring financial relationships for use of these shared spaces. The webinar is intended for provider organizations’ executive staff, project planners, and legal counsel.

Stark Law and Integrated Health Care Webinar
Wednesday, June 29
12:00 – 1:00 pm
Register today

  • RCPA member registration is $25
  • Non-member registration is $40

Presenter: Ms. Martin exclusively practices health care law and advises both individual and institutional health care providers on regulatory and transactional matters. A significant portion of her practice centers on mental health and substance abuse law, including HIPAA, informational privacy, and fraud and abuse compliance. Ms. Martin has assisted in the formation of regional health information centers and mental health medical homes, working closely with federally qualified health centers and mental health providers.

RCPA will now distribute INFOS and ALERTS covering research, delivery and training models, policy issues, and other topics that will inform our members about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

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The Centers for Medicare and Medicaid Services (CMS) will conduct a call on the key quality measures related to the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 and how they will affect providers. The IMPACT Act requires the reporting of standardized patient assessment data on quality measures, resource use, and other measures by Post-Acute Care (PAC) providers, including inpatient rehabilitation facilities, skilled nursing facilities, home health agencies, and long-term care hospitals. The call is scheduled for Thursday, July 7, 2016 from 1:30 to 3:00 pm ET. Those interested in participating are encouraged to register early as space is limited.

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On May 3, 2016, the Centers for Medicare and Medicaid Services (CMS) issued an update to the additional documentation request (ADR) limits for Medicare institutional providers under the Medicare fee-for-service (FFS) recovery audit program, which will allow recovery audit contractors (RACs) to request more documents from providers who have high claims denial rates.

For example, a provider with a 0 to 3 percent denial rate will receive no additional RAC document requests for three 45-day review cycles, while providers with denial rates between 91 percent and 100 percent could potentially receive RAC document requests of up to 5 percent of their paid claims. A baseline annual ADR limit is established for each provider based on the number of Medicare claims paid in a previous 12-month period. Using the baseline annual ADR limit, which is one-half of one percent (0.5%) of the provider’s total number of paid Medicare claims from a previous 12-month period, an ADR cycle limit is also established. After three 45-day ADR cycles, CMS will calculate (or recalculate) a provider’s denial rate, which will then be used to identify a provider’s corresponding “Adjusted” ADR limit. Recovery auditors may choose to either conduct reviews of a provider based on their adjusted ADR limit (with a shorter look-back period of six months) or their baseline annual ADR limit (with a longer look-back period of three years).

Questions concerning this update can be submitted via email.

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