"Physical therapy is not a subspecialty of the medical profession and physical therapists are not medical doctors; we are a separate profession that provides a unique service that physicians are unable and untrained to provide."

Letter to the AMA from the APTA, Dec 2009

Friday, August 13, 2010

Physical Therapist´s Payment Option #2

This is the second option discussed in the 2011 Proposed Medicare Physician Fee Schedule published in the Federal Register on June 25th, 2010 and open for public comment until August 24th 2010.  The first Option is discussed here.

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.

Option #2

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...".
Benefits: None are obvious to me. This seems like 2006 Therapy Cap Redoux

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.

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Tim Richardson, PT owns a private practice at Medical Arts Rehabilitation, Inc in Palmetto, Florida. The clinic website is at MedicalArtsRehab.com.

Bulletproof Expert Systems: Clinical Decision Support for Physical Therapists in the Outpatient Setting is a manager's workbook with stories, checklists, charts, graphs, tables, and templates describing how you can use paper-based or computerized tools to improve your clinic's Medicare compliance, process adherence and patient outcomes.

Tim has implemented a computerized Clinical Decision Support (CDS) system in his clinic since 2006 that serves as a Reminder, Alerting, Prompting and Predicting CDS using evidence-based tests and measures.

Tim can be reached at
TimRichPT@BulletproofPT.com .

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