Let’s say that you are sitting at home reading your favorite blog (evidence in motion of course) and you receive a call from your Senator or Congressperson. They ask you to provide rational for the extension of the exception process, what would you tell them? Different question. Let’s say they call and ask you why Medicare should get rid of the outpatient PT cap, what would you tell them? Which is easier to defend? Which gets you more enraged?
Enough said.
Besides, isn’t implicit in supporting a moratorium on a cap and an extension of an exception process really supporting a cap?
Many emailed me on the side and the comments are also insightful. Why does CMS spend so much time monitoring a cap and supporting an exception process when outpatient PT is 1.5% of their expenses? Isn’t that just a tad overkill? Yes it is.
The reason that CMS cares is that although it is 1.5%, it is growing. But, so is the overall Medicare program. Growth by the way doesn’t justify a cap either. If the growth was due to the increase in number of patients exceeding the cap (which by the way that is a small percent further supporting the stupidity of a cap in the first place) that would be one thing but it is due to overall growth in numbers of patients receiving PT. Again, this can be a good thing and a good place for CMS to spend money as there are countless sources that demonstrate spending a little on PT will save you a bundle on imaging, surgery, pharmacy-key cost drivers for CMS. Additionally, and more importantly, if CMS is really into growth and monitoring costs they should move monitoring costs over from cap/exceptions process to being able to track one of the key drivers to PT growth-POPTS and self-referral. Right now, CMS has no real way to distinguish provider source growth.
Due to relaxation of the Stark provisions as well as ambiguous OIG clarifications, opportunistic docs and PT’s have caused proliferation of self-referral situations-the real cause of PT growth volume in the CMS system. The relaxation of those rules and the fact that many providers are comfortable driving 80 miles an hour in a 55 mph zone, has metastesized in the form of“satellite” PT offices for physicians. I am aware of more than one geographic area that is dominated by more physician PT clinics than independents!
On a side note, there is a little bit of good news. Over 1,100 comments to CMS regarding POPTS and although no response, it has to be on their radar.
On a side note, getting rid of these “satellites” should be priority numero uno for our profession as it can be accomplished. Many states have put regulations in to ban them due to an unrelated phenomena that occurs with physicians and multiple laser hair removal centers satellites that they “supervise”(by the way, the qualification in many states for a laser operator is the ability to identify an electrical socket, hold on to a handle, and in one breath say “this is going to hurt a little”). This movement is a bandwagon that we need to jump on but apply it to PT. History has shown that this is exactly the type of collaboration that we should have jumped on including regulations that were put in place to ban specialty hospitals, self-referral in imaging, pharmacy and the like. We are too small to fight this alone-we need to combine with other groups fighting similar causes.
Enough.
Thoughts?
