CMS Releases Proposed Rule for 2019 for Therapy Services
On July 12, 2018, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule: “Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program”. This proposed rule has several proposed changes for outpatient therapy services beginning with dates of service on and after January 1, 2019.
Highlights of the proposed rule include the following:
- Functional limitation reporting
- Revised description for GN, GO and GP discipline specific modifiers
- New modifiers for services provided by a physical therapist assistant (PTA) or occupational therapy assistant (OTA)
- Merit-Based Incentive Payment System (MIPS)
- Revise direct practice expense inputs for 3 CPT codes utilized by physical and occupational therapy
Lets begin!
1. Functional Limitation Reporting
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Rick-
Do you have any idea what the rationale for eliminating the FLR is?
Yes! It was burdensome and provided useless data to CMS. In addition, CMS found they were not useful in considering how to reform payment for therapy services as an alternative to the therapy caps.
Which is what we as therapists told them when the FLR was first proposed.
Thank you.
Is there any way to discover the amount of money Medicare spent (wasted) in implementing and managing FLR?
My opinion, no.
Where can I find more information about MIPS? Will have any webinars on MIPS?
Thank you
Diane
I will do a webinar on MIPS in late November or early December once the final rule is published.
where can we find the MIPS quality measures for PT & OT
It’s in the proposed rule in Appendix B.
Does MIPS apply to rehab agencies?
Please read number 4 in this article and it states who MIPS will apply to.
Do you know if anyone, APTA etc.., is fighting the PTA & OTA reimbursement cuts? Or does it seem to be a done deal?
Thanks,
Shay
APTA and AOTA will be addressing it with CMS.
Can you post a link to Appendix B that you mentioned above? I can’t find it on Medicare’s terrible website.
At the end of this article is a link to the proposed rule. Appendix B is at the end.
Do you know if the MIPS rules will apply only to private practice and not SNF, IRF, and other UB04 billers (similar to PQRS)?
Please read number 4 in this article and it states who MIPS will apply to.
Is EF028 really billed in outpatient private practice? I have never heard of this code or know how to use it.
I do not know what EF028 is.
To a small out patient OT and PT private practice, that is not using EMR at this time, how will this new MIPS system effect us ?
We will not know the complete roll out of MIPS until the final rule is released on or around November 1, 2018.
I am concerned that the modifier is the same whether the visit is provided “in whole or “in part” by a PTA. Those are VERY different scenarios! Has APTA considered pushing back on that?
lynn
My opinion is that APTA will provide suggestions on what “in part” means and looks likes.
We are not medicare/medicaide providers. Is that a requirement for participation?
If you do not treat Medicare patients, then this proposed rule would not apply to you.
With PDPM they are saying PT and OT will cap at 25% of total therapy time yet we were not going to have to track the minuets so will the 25%caps be enforced with the entire therapy stay?
In what setting are you asking this question for?
This is all very interesting. Just curious if you know how payment is affected for Physcian Assitance.
What do you want to know about physician assistant payment under the Medicare program.
CMS recently published their proposed rule for 2019. If the proposal goes into effect, therapist will join the list of providers who must participate in the CMS Quality Payment Program. Since we are hospital-based OP rehab departments and ambulatory clinics, will this apply to us. We file to Medicare Part A using a group PTAN and group NPI #.
MIPS is only for therapists in private practice.
Any updates on if FLR will be removed in 2019?
The final rule is due out on or around November 1, 2018. Watch for an updated article on my website.
With FLR ending Jan 1st, will clinics need to continue reporting to complete claims rolling over into 2019. Or can they just stop all reproting as of Jan 1st?
Last date of service to report FLR is December 31, 2018.