Reimbursement

CPT 2008: New Codes

Do you have questions regarding coding changes?  Can your office afford to not understand all of the latest changes and rulings?   The APTA website has the answers to your questions.  Just click on reimbursement and follow the links that meet your needs.  This is a member only benefit, so remember this is another reason it pays to be a member. 

The 2008 version of CPT includes new codes pertaining to Non Face-to-Face services including telephone assessment and management services, and online evaluation and management services. There are also new medical team conference codes. The following includes a description of each of the new codes and guidance in their use. Please note that the heading language for these new codes is extensive and provides considerable guidance as to the requirements for use of the codes.

It should be noted that the Centers for Medicare and Medicaid Services released the 2008 Physician Fee Schedule in the final rule published on November 1, 2007. The rule, which will be printed in the Federal Register November 27, 2007, includes Medicare's determination that they will not pay for any of the new services described below. The rule can be found at: https://www.cms.hhs.gov/center/physician.asp.

APTA was very active in both the interdisciplinary development of these new codes as well as the valuing of these codes through the AMA CPT process. It is unfortunate that Medicare's decision is not to pay for these services. It is unclear whether or not private payers will have the same coverage policies for these services. These codes, however, are available for physical therapists to report.

Physical therapists should become familiar with the new codes and their heading language.  APTA is interested in any feedback you can provide pertaining to payment of these services by private payers. Please forward any feedback to reimbursement@apta.org.

New ICD-9 Code Changes 

Please refer to the APTA website for new and invalid ICD-9 codes.  This is a member only benefit.

"Red Flag Rules" Delayed
The Federal Trade Commission just announced that it will delay enforcement of the new "Red Flags Rule" until August 1, 2009, to give creditors more time to develop and implement written identity theft prevention programs. Physical therapists and other healthcare providers who provide services to patients without requiring those patients to pay in full at the time of service will need to comply with the "Red Flag Rules" that require the development of an Identify Theft Prevention Program. These rules require that they make reasonable attempts to prevent and detect identify theft and take action to mitigate identity theft if it occurs. To assist with compliance, the FTC will soon release a template to help entities that have a low risk of identity theft, such as businesses that know their customers personally. More information on the "Red Flag Rules" is available on APTA's website by clicking here: http://www.apta.org/AM/Template.cfm?Section=Fraud_and_Abuse&Template=/MembersOnly.cfm&ContentID=57432&Token=6B0654A6-9FBD-43AB-A6B8-85CDFE271783.The FTC announcement of the delay until August is available at: http://www.ftc.gov/opa/2009/04/redflagsrules.htm

Rescission of Medicaid Outpatient Hospital Rule
On May 5, 2009, CMS published a rule that proposes to rescind a previous final rule entitled "Clarification of Outpatient Hospital Facility Services Definition". CMS states that since the publication of this rule, the Agency has realized the adverse effects and restrictions to access to care that may result from implementation of the regulations. This rule, which was finalized in November of 2008, seeks to more closely align the Medicaid definition of outpatient hospital services more to the Medicare definition. If implemented this rule could have detrimental effects on Medicaid patient access to physical therapy services in the outpatient hospital setting. APTA has been very involved with trying to block implementation of this rule and will be recommending for rescission of the rule by the June 1, 2009 comment deadline.

CMS Proposes Payment and Policy Updates for Skilled Nursing Facilities
On May 1, 2009, CMS released a proposed rule that would update the payment rates for skilled nursing facilities (SNFs) for fiscal year 2010 by 2.1 percent or $660 million. The rule also seeks to reduce SNF payments by $390 million, or 1.2 percent lower than payments for FY 2009. This adjustment in SNF payments is an effort to rebalance an earlier adjustment to the case-mix indexes (CMIs).
In addition to recalibrating and updating the SNF PPS payment rates for FY 2010, this proposed rule:
 * Proposes a revised case-mix classification methodology (RUG-IV) and implementation schedule for FY 2011, reflecting updated staff time measurement data derived from the recently-completed Staff Time and Resource Intensity Verification (STRIVE) project;
 * Invites comment on a possible new rate component to account for the use of non-therapy ancillaries (as recommended by MedPAC);
 * Includes information on the transition to the Minimum Data Set, Version 3.0 (MDS 3.0) redesigned nursing home resident assessment instrument, including an implementation schedule; and
 * Invites comment on a possible new requirement for the quarterly reporting of nursing home staffing data.
For further information, see www.cms.hhs.gov/center/snf.asp. Public comments on the proposal will be accepted until June 30, 2009. A summary of the proposed rule will also be available on the APTA website shortly.
CMS Issues Proposed Payment and Policy Updates for IRFs for 2010
The Centers for Medicare and Medicaid Services (CMS) released a proposed rule http://www.federalregister.gov/OFRUpload/OFRData/2009-10078_PI.pdf for payment of inpatient rehabilitation facility (IRF) services for FY 2010 that updates payment rates and clarifies criteria for selection of patients for admission to IRFs and care in the IRF setting. In addition to the proposed rule, CMS posted draft revisions to the Medicare Benefit Policy Manual that are open for public comment.

Of note in this proposal are several changes to the coverage requirements for IRF services. CMS believes these changes reflect an increased emphasis on the role of the rehabilitation physician in ordering these services and providing ongoing oversight of beneficiary care. Specifically, if adopted, this rule would require a comprehensive preadmission screening completed by a rehabilitation physician no more than 48 hours prior to admission to the IRF and a post-admission inpatient assessment to be completed within 24 hours of admission. Therapy services would need to commence within 36 hours of admission to the IRF and an individualized overall plan of care by an interdisciplinary team would need to be developed within 72 hours of admission. Additionally, CMS has proposed a face-to-face visit with the patient by the physician at least 3 days a week, and the interdisciplinary team would be required to meet weekly, as opposed to every 2 weeks as is the currently requirement. The agency also is considering eliminating the use of group therapy and is seeking comment on this proposal.

CMS has prepared fact sheets that summarize the changes to the payment https://www.cms.hhs.gov/apps/media/press/factsheet.asp?Counter=3444&intNumPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchData=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=&cboOrder=date and coverage https://www.cms.hhs.gov/apps/media/press/factsheet.asp?Counter=3445&intNumPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchData=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=&cboOrder=date provisions of the proposed rule. Comments on this proposal will be accepted through June 26 and a final rule will be issued by August 1. A summary of these provisions also will be available shortly on APTA Web site.

Medicare Online Enrollment (PECOS)
In December 2008, CMS implemented an online process for Medicare enrollment. The Provider Enrollment, Chain and Ownership System (PECOS) will allow most providers and suppliers to use an Internet-based system to enroll in Medicare, make a change in their Medicare enrollment information, view their existing Medicare enrollment information, voluntarily withdraw from the Medicare program, or check on the status of an Internet-submitted Medicare enrollment application. PECOS is available to physicians and non-physician practitioners in all 50 States and the District of Columbia.

For additional information on PECOS, you can visit the APTA web site by clicking here: http://www.apta.org/AM/Template.cfm?Section=Become_a_Provider_Supplier&Template=/TaggedPage/TaggedPageDisplay.cfm&TPLID=166&ContentID=36012 or you can go directly to CMS Web site at https://pecos.cms.hhs.gov/pecos/login.do

This is not all inclusive of reimbursement issues and education for physical therapy.  Please go to www.apta.org and click on reimbursement for more information. 

Reimbursement Chair Meeting - Save the Date
The 2009 Reimbursement Chair meeting is scheduled for Friday and Saturday, November 20th and 21st at the Sheraton - Crystal City, Arlington VA.

Stay tuned for additional details regarding 2009 Reimbursement Chair Meeting.