Wyoming Physical Therapy Association

Reimbursement

WYPTA GOVERNMENT AFFAIRS UPDATE

Contract negotiations.  Look at all contracts you have with insurance companies. You should review them 6 months before they expire and start renegotiating at that time.

Copay legislation has passed in many states limiting high PT copays

The Affordable Care Act exchange participation starts October 1,2013. Wyoming has chose to go with the federal exchange program and the information related to that is not expected to be known until October 1.  Once they are published I will get information on the website related to how they may affect PT practices.  It currently is very confusing in states that are creating their own exchanges with little information being disseminated.

Support the Promoting Integrity in Medicare Act and Help Close the Physical Therapy In-Office Ancillary Services Exception - On August 1, 2013, Congresswoman Jackie Speie (D – CA, 14th) introduced the Promoting Integrity in Medicare Act, H.R. 2914.  This bill closes the in-office ancillary services (IOAS) exception under the physician self-referral prohibition, commonly known as the Stark Law.   The Promoting Integrity in Medicare Act removes physical therapy, as well as advanced imaging, radiation oncology, and anatomic pathology from the IOAS exception.  If passed, this legislation will help curb unnecessary utilization, decrease spending, and lay the groundwork for payment reform.   APTA has long been opposed to referral for profit (RFP) in physical therapy, also known as physician-owned physical therapy services (POPTS), and has been working for years at the national and state level to close this exception.  Please take action today and help end physician owned self-referral.  Ask your Rep Lummis to support the Promoting Integrity in Medicare Act (H.R. 2914).

On February 14, Congressmen Jim Gerlach (R-PA) and Xavier Becerra (D-CA in the House of Representatives and Senators Ben Cardin (D-MD) and Susan Collins (R-ME) in the Senate introduced “The Medicare Access to Rehabilitation Services Act (H.R. 713/S. 367).” This legislation will repeal the cap on therapy services for Medicare beneficiaries once and for all. If Congress does not take action by December 31, 2013, the therapy cap will again be imposed on Medicare-covered physical therapy, occupational therapy, and speech language pathology services. We need to take action NOW to ensure the cap does not go back into place.  Please contact our members of Congress and ask them to cosponsor legislation to repeal the therapy cap (H.R. 713/S. 367) once and for all.

Support the Medicare Patient Empowerment Act of 2013 (H.R. 1310)  Currently, physical therapists do not have the ability to privately contract with Medicare beneficiaries, unlike other healthcare providers. The Medicare Patient Empowerment Act of 2013 (H.R. 1310) would allow physical therapists and other providers to contract with Medicare beneficiaries.  As Medicare reimbursement and regulations continue to challenge those serving in health care, it is imperative for providers to maintain the ability to choose what is most appropriate for our practices. Email Representative Lummis today and urge her to cosponsor the Medicare Patient Empowerment Act of 2013 (H.R. 1310).

Support the Physical Therapist Workforce and Patient Access Act
 On March 19, 2013, The Physical Therapist Workforce and Patient Access Act of 2013 (H.R. 1252/S. 602) was reintroduced in the US House of Representatives by Representatives John Shimkus (R-IL) and Diana DeGette (D-CO), and in the US Senate by Senators John Tester (D-MT) and Roger Wicker (R-MS). This legislation authorizes physical therapists to participate in the National Health Service Corps (NHSC) Loan Repayment Program.  The NHSC addresses the health needs of over ten million underserved individuals at 14,000 sites across the nation.  H.R. 1252/S. 602 would ensure that patients receive access to physical therapy services to meet the needs of both rural and underserved areas. As physical therapy workforce shortages continue to grow, it is essential that physical therapy be added to the list of professions included in the NHSC program to guarantee patient access in underserved communities.  Ask our members of Congress to take action to support the physical therapist workforce and increase patient access in underserved communities by cosponsoring H.R. 1252/S.602.

APTA is working on maintaining the integrity of the profession.  They have instituted a publics relations campaign fighting fraud and abuse so we do not become like DME.  Initial resulted will be presented at CSM 2014 with various presentations and educational offerings.

APTA is developing a registry system for outcomes management.  This will help with compliance and practice guideline development.

REIMBURSEMENT UPDATE

Functional limitation reporting (FLR) stated on July 1,2013. All Medicare beneficiaries have to have the FLR G codes reported at evaluation, every 10 visits and at discharge. APTA reported that full implementation has not occurred yet with Medicare. You may notice payment even if you forgot to report G codes.  The recommendation is to report them once you realize the error.   Full implementation will occur and you do not want to be taken by surprise with nonpayment of claims.
If you have a patient with multiple diagnosis, only report G codes on 1 diagnosis.  When you discharge that diagnosis you can start reporting on any other diagnosis they still might require treatment for. If a patient is being seen by 2 therapists for 2 different diagnoses only report on 1 diagnosis.  Visit count will accumulate for both diagnosis though so the 2 therapists need to coordinate to make sure the reporting therapist is aware of when the 10th visit is going to occur.

Trigger point dry needling coding.  APTA recommends using 97799unlisted procedure to document trigger point dry needling.  Medicare does not have any terminology under any CPT code describing trigger point dry needling.  Many therapists use 97140 but it is not covered under the original vignettes that created that code.  It is recommended to give Medicare patients an ABN stating it is a non covered service and charging them cash for this procedure.  If you use 97799Medicare will request notes and then deny the code.  Another option is remembering the 8 minute rule.  Many times TDN is a component of other manual therapy techniques and does not utilize a full unit of treatment. You may be able to bundle it with other services to meet the 8 minute rule requirement.
Wyoming Workers Compensation requires the use of 20999 for all trigger point dry needling.

Other insurances are starting to use the multiple payment reduction. These include Humana and Aetna.

An ABN can not be given out until a non covered service presents itself. Do not have Medicare patients sign them when they start care.

Medicare has increased it's recoupment efforts. More clinics are undergoing audits from RA and CERT auditors.  Do not ignore these.  Watch all dates carefully and respond promptly.  It is recommended to send all informational certified mail as there have been reports of denials based on non-response when actually the clinics had sent everything in.  The auditors are trained for recoupment and are paid a commission of what they recoup.  It is recommended to appeal all denials, they are counting on providers not taking the effort to challenge them.  Please let me know of any audits so APTA can be made aware of any trends that could be happening with appeals and denials.

Prepayment review of Medicare claims exceeding $3700 is a mess.  We are in a postpayment state so may be a bit luckier.  I need to know if anyone has undergone a postpayment review in 2013 and what the result was.  The only way APTA and I can help members is by seeing what responses they have been getting.