Per our previous post, July 10th was the deadline to submit comments to the Committee on Ways & Means regarding Medicare’s payment policy for outpatient therapy services.  I gave mine and hopefully many of you also submitted (of course that is if you weaved your way around the directions).

I decided to peruse thru comments of various national organizations that PT is an “interested party”.  Imagine my surprise when the headline this past friday’s APTA digest read “APTA Urges Therapy Cap Repeal to House Committee”.  I thought this is exactly what we need.

Until of course, I read the fine print (available for members only here.  If your not a member, you should be so join here) in which it details that the cap should be repealed beginning January 2011!  In the interim, they should refine the cap exceptions process.  You have got to be kidding right.  Is anybody that actually goes thru the exceptions process writing this?

I have mentioned many times on this blog that the exceptions process is a complete waist of time that only increases our cost (thereby effectively reducing our reimbursement) and does not serve the purpose that it was intended due mostly to “gaming” the rules.  Why should we not be so bold to call it what it is and end the cap and the exception process immediately?

Lest you think I am beating up our beloved national organization up too much, let me also cite that the vast majority of the comments made by APTA were outstanding and strategic (except the self-served recommendation to integrate OPTIMAL as a standard assessment instrument-I will leave criticism of that for another time).

For example, APTA recommends elimination of “ancillary” and “in office” exemption (essentially eradicating POPTS).  A bold proposition (why couldn’t we be bold enough to completely repeal the cap and exception process?) that the majority of our membership supports.  As justification for this recommendation, their rational included the obvious perverse financial incentives for self-referral (even associating in-house PT with other self-referral culprits-labs, and imaging) and the 2004 OIG study that showed that the majority of referrals to in-house do not meet standards of outpatient therapy.

Furthermore, the recommendation that all medicare data be provided by independent supplier status (essentially every PT’s medicare claims being tracked to that individual) supports the notion of PT as autonomous and accountable.  I recommended that data by practice type by tracked so that we can differentiate medicare data by PT in private practice from POPTS and I believe the coupling of this with APTA’s recommendation would be immensely helpful.

I hope many of this blog sent comments to CMS.  We are all in this together.

Thoughts?

Larry