Three new poposed payment options related to the Medicare Physician Fee Schedule were published in the June 25th Federal Register and are available for public comment until August 24th.
The immediate concern is the proposed Multiple Procedure Payment Reduction (MPPR) policy but there are additional concerns that deserve physical therapists´ attention. I´d like to review the alternative payment options:
- Option #1
- Option #2 and
- Option #3
Note that CMS is not specifically recommending these alternative payment policies, at this time.
Option #1: New Severity and Function codes
The Centers for Medicare Services (CMS) would require physical therapists to replace the -KX modifier with new HCPCS Level 2 codes at Evaluation and Progress Note intervals (30 days or 10 visits, whichever is less).
|PT Test or Measure||Function Codes||Code Description|
|Impaired Step Down Test||GxxxU||Body Function/Body Structure impairment - current|
|Impaired Step Down Test||GxxxV||Body Function/Body Structure impairment - goal|
|Slow Stair Measure Test (9 steps)||GxxxW||Activity Limitation/Participation Restriction - current|
|Slow Stair Measure Test (9 steps)||GxxxX||Activity Limitation/Participation Restriction - goal|
|3 steps into home||GxxxY||Environmental Barrier - current|
|3 steps into home||GxxxZ||Environmental Barrier - goal|
note: I have added the PT Tests and Measures to show how these codes might be supported by evidence-based data in the patient chart.
Two severity modifiers have been proposed. This first chart shows modifiers based on the ICF:
This second chart shows modifiers for impairments, limitations and/or barriers as simple percentages:
|1 to 19%|
|20 to 39%|
|40 to 59%|
|80 to 99%|
Benefit: The policymakers are using International Classification of Function (ICF) descriptors to link physical impairments to function in a way that can be analyzed through claims reporting.
This option explicitly defines patient progress by comparing current and expected (goal) function.
CMS believes this option will lead to a decreased reporting burden because the -KX modifier would not be need on each claim line for patients over or near the PT caps. Instead, only the new severity and function codes would be reported at (re)evaluation and Progress Note intervals.
These codes would also provide more information for medical review - at this time medical review (Medicare Audit) is a highly variable process that imposes provider liability based on largely pen-and-paper scribbled, narrative notes.
Risk: Physical Therapists in Private Practice (PTPPS), hospitals outpatient departments (Part B) and other settings may not routinely assess firsthand patient environmental barriers, especially those in the patient´s home.
Also, the link between physical impairment (body structure and function) and functional limitations (Activity and Participation Limitations) is tenuous and poorly described in the PT literature.
If such a link does exist it is probably NOT the linear, staight line conceptualized by Nagi in 1965 or the ICFDH in 1981.
This new coding scheme seems to hold physical therapists accountable for a conceptualized framework that is popular to academics and policymakers but is often absent from clinical realities.
Time Frame: Six months to two years.
My Call: I like this option because it gives physical therapists the chance (for the first time) to send claims-level data to CMS about the quality of physical therapy.
This option may protect physical therapists from the Medicare Auditors´ concept of "skilled physical therapy" as a reason to deny claims.