Update On Efforts To Reduce The Planned 2021 Payment Cuts To Therapy

physician fee schedule

CMS’ proposed physician fee schedule for 2020

There has been much concern surrounding the US Centers for Medicare and Medicaid Services’ (CMS) proposed physician fee schedule (PFS) rule for 2020. It is a wide-ranging plan that impacts multiple types of providers. Physical therapists (PTs), occupational therapists, physical therapist assistants (PTAs), occupational therapist assistants (COTAs) and the patients they serve are facing a particularly pointed threat: a cut to the reimbursement codes most often used in physical and occupational therapy. Combined, these reductions would reduce reimbursement by an estimated 8% in 2021.

As per the AOTA “AOTA is concerned with the potential for an 8% decrease to therapy services in 2021. AOTA is advocating against this reduction and will be sending comments to CMS both individually as an organization, and as part of a joint coalition letter with the American Physical Therapy Association (APTA) and other impacted specialties that do not bill for E/M codes. In addition to our advocacy work with CMS, AOTA Federal and Regulatory Affairs staff have been collaborating closely with APTA to flag our concerns about these policies with Congressional leaders and their staff. Even after the CMS comment period is closed, we will continue our work to educate Congress about these reimbursement challenges.”

Recently a bipartisan letter to CMS was signed by 99 members of the U.S. House of Representatives who are concerned about the agency’s plan to make cuts to Medicare (including the 8% reduction to therapy codes).The  American Physical Therapy Association led efforts to inform legislators of the issue.

In the letter sent on February 5th; the representatives write that their constituents have concerns about whether the planned cuts will reduce access to health services. In order to respond to those concerns, the legislators are asking about the process CMS used to reach the decision to reduce the reimbursement for services furnished by certain providers in 2021 in order to accommodate increases to values of the office/outpatient evaluation and management codes, known as E/M codes.

“The letter specifically asks CMS to explain the methodology and data the agency used to calculate the estimated impact to each specialty level impact associated with the coding change, and to provide a description of the factors the agency considered in deciding how much it would reduce each of the 36 other professions selected for cuts.

The legislators also pressed CMS on its statement that it would consider additional information before making a final decision, asking what kind of information would be of the most value, and whether CMS considered how the proposed changes could impact access to care — and if so, how.

The letter requests that CMS respond to Congress by February 21.”

In addition to this, thanks to the efforts made by Brenda Mahlum, DPT, the APTA Federal Affairs Liaison for the Montana Chapter, Senator John Tester (D) also sent a letter to the agency describing his concerns that the cuts “will compromise patients’ access to care, particularly in the most remote areas of my state and across the country.”

“Medicare beneficiaries increasingly rely on physical therapy and occupational therapy services as part of a coordinated model of care,” Tester writes, adding that the planned cuts run the risk of drying up access to care in underserved and rural areas that are already struggling to meet health care needs. “Payment decisions like the ones in this final rule will limit provision of services,” Tester adds. “The physical therapists and occupational therapists in Montana operate on very narrow margins, and any reimbursement reductions may jeopardize their ability to remain open and serve their patients.”

Justin Elliott, APTA’s vice president of government affairs, sees member engagement as the driving force behind the legislators’ efforts.

“We are grateful to Representatives Buddy Carter and Lisa Blunt Rochester for their leadership on this bipartisan House letter to CMS, and even more grateful to the APTA members who urged their legislators to get on board,” Elliott said. “The large number of bipartisan signatories to the letter should demonstrate to CMS that the public needs more information to understand what policy goal this flawed proposal is trying to achieve. We understand and support the desire for increased payment for the E/M codes. However, we believe it’s inappropriate to reduce payment to physical therapists and 36 other provider groups as the way to pay for it.”

The APTA and AOTA strongly advise all members to act at this critical time. As per the AOTA:

“AOTA strongly encourages members to submit individual comment letters identifying their concerns to CMS by the September 27 deadline. Please feel free to use the arguments outlined below in your own comment letter, which can be submitted directly to CMS. We understand that due to budget neutrality, when increases are made to some codes, reductions must be made in others. However, the proposed 8% decrease to therapy services would be highly detrimental to the profession of occupational therapy, especially coupled with the other cuts that therapy services have taken in recent years and will continue to take with the OTA payment reduction in 2022.

Because therapists cannot bill E/M services, we will not receive any of the benefit of the increases to balance out the cuts to our professional services. The cumulative nature of MPPR, sequestration, and the OTA payment modifier is already substantial and hard felt, particularly by practitioners in rural and underserved areas, and those occupational therapy private practices may need to reduce operations or close their small businesses altogether. The aging population is in greater need of occupational therapy practitioners than ever before. Access to these services is essential, but a single reimbursement cut this large may make practicing unsustainable for the profession. We urge CMS to reconsider the distribution of payment reductions for budget neutrality.

Email regulatory@aota.org if you have questions or wish to offer additional comments.”

The APTA has dedicated a page on their website to this issue at http://www.apta.org/FightTheCut/ 

A common theme resonated by these organizations is that there is strength in numbers. They are highly encouraging action by clinicians, business owners, patients, students and anyone else impacted by these proposed changes. They offer templated letters to make it quick and easy to express your concerns and join the efforts to reduce the impact or eliminate the upcoming cuts. 

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