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.
A new PT therapy cap will be determined "...based on existing therapy utilization...
- such as limits to the number of services per session,
- per episode or
- per diagnostic grouping...".
Risks: Plenty. The risk of a Medicare Audit if you appeal the automatic denial (no -KX modifier with this option) and deliver needed therapy services to thosepatients who need them.
The therapist is left holding the bag with no ability to justify needed services beyond the technology that exists today. Physical therapist liability is increased, documentation burden is added and no financial improvement is evident.
As I identified in Option #1, PT liability is incurred because Medicare Auditors can deny services day-by-day or even line-by-line based on their arbitrary determination of "skilled physical therapy".
Time Frame: 1 to 2 years to implement.
My Call: Option #2 is just the same old, same old - again, a redoux of the 2006 Manual Exceptions process that confused many therapists and left the patient, in many cases, without needed services beacuse the regulations were too confusing.