You can submit your comments directly to Medicare using this link. According to the American Physical Therapy Association (APTA):
If you attach the document, please make sure to include a statement in the text box (e.g. “I am attaching comments in response to the proposed physician fee schedule rule. Thank you for your consideration.”)Please note that this blog is independent of the APTA and my opinions or blog posts are not in any way associated with the APTA.
Twelve new Evaluation and Intervention (E/I) codes that would capture the History, Physical Examination and Medical Riskiness of the physical therapy evaluation.
|None||E/I code #1||E/I code #2||E/I code #3|
|Minimal||E/I code #4||E/I code #5||E/I code #6|
|Moderate||E/I code #7||E/I code #8||E/I code #9|
|Significant||E/I code #10||E/I code #11||E/I code #12|
A Significant complex evaluation with Significant interventions would rate a #12 E/I code - the highest payment. Most of the PT diagnoses would be codes #4-9. Also, only physical therapists, physicians or non-physician practioners could bill codes #1-3 and #7-12. Physical therapy assistants could also bill codes #4-6.
Physician Evaluation and Mangement codes are discussed here and using the Interactive Worksheet at First Coast Service Options (Florida Carrier/Intermediary).
Benefits Option #3 represents the closest approximation to physican Evaluation and Management codes that are valued based on...
- Physical Examination
- based on the number of body systems reviewed and
- Medical Decision Making that looks at
- Number of Diagnoses
- Amount of Data reviewed (eg: lab results)
- Risks associated with medical decisions
Moving away from Fee-for-Service in this way may reward quality over quantity. Is it possible that the very best physical therapists could see HIGHER reimbursements as they learn the new system and finally get paid better than their "average" peers?
Risks Physicians overutilize testing, mainly diagnostic imaging, in order to reduce professional liability. This reliance on expensive, modern testing drives up healthcare costs and increases the incidence of false-positives, physiologic diagnoses and inappropriate surgeries.
Fortunately, physical therapists do not share this risk. Greater data collection to reduce Medciare Audit risk SHOULD be a goal of any alternative payment system.
Bundled payments, however, are unfamiliar to most small medical providers and may provide inadequate reimbursement for the most complex cases.
Time Frame: 2 to 4 years to implement.
My Call: This is an option I would like to see discussed further - if only for the reason that it suggests that physical therapists can and do make decisions of similar comprehensiveness, complexity and riskiness as physicians.