Action Alert for PTs, PTAs & Students: Please Oppose Flawed Proposed CMS PolicyPosted: Aug. 26, 2019 On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the 2020 Medicare Physician Fee Schedule (PFS) proposed rule. Within this rule, CMS puts forth additional guidance regarding application of the new therapy assistant modifiers (CQ/CO modifiers for outpatient therapy services furnished by PTA or OTAs respectively). This builds upon CMS’s guidance issued in last year’s PFS final rule. Now that the 2020 PFS proposed rule has been released and APTA has had a chance to review the proposed policy, APTA (and AOTA and other stakeholders) have serious concerns. In APTA’s view, the modifier policy proposed in this rule is not only inherently complex, but it is a gross overreach of CMS’s statutory authority, is not in line with congressional intent, and would result in drastic underpayments for outpatient therapy services beginning in 2022, severely restricting beneficiary access to vital therapy services, particularly in rural and underserved areas. The policy fails to put the needs of the patient first and ignores the therapist’s active engagement in treatment, reducing reimbursement not only for the assistant’s services but also the services performed by the therapist. Moreover, if CMS adopts this flawed policy, not only will it negatively impact providers treating Medicare beneficiaries, but commercial payers are likely to adopt the same flawed policy, thereby negatively impacting all outpatient physical (and occupational) therapy providers. APTA is asking all PTs, PTAs, and students of physical therapy to submit comments to CMS opposing the proposed application of the 10% de minimis standard, using APTA’s template letter. It only takes 5 minutes! The template letter for clinicians and the template letter for patients can be found on APTA’s Regulatory Issues: Take Action webpage. Copied below is where the template letters can be found on the webpage. The letters can be accessed and personalized by anyone – members and non-members.
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