* * *
I am an occupational therapy assistant student residing in
I. Proposed E/M Policy and Related Cuts for 2021
I understand that due to budget neutrality, when increases are made to some codes, reductions must be made to others. However, the proposed 9% decrease to therapy services would be highly detrimental to the profession of occupational therapy, especially coupled with the other reimbursement cuts that therapy services have taken in recent years, and will continue to take with the OTA payment reduction, which is effective in 2022.
The cumulative nature of MPPR, sequestration, and the OTA payment modifier is already substantial and hard felt, particularly by practitioners in rural and underserved areas. As a result, occupational therapy private practices and outpatient clinics may need to reduce operations or close their small businesses altogether. Moreover, the aging population is in greater need of occupational therapy practitioners than ever before. Access to these services is essential for Medicare beneficiaries who wish to age in place, particularly for the growing demographic with chronic conditions, but a single reimbursement cut of this magnitude may make practicing unsustainable for the profession.
For example, the 9% payment cut will significantly impact my future being in the state I live in
While the work Relative Value Unit (RVU) increases to therapy evaluation and re-evaluation codes is appreciated, the increased value does not adequately off set the cuts to therapy intervention services.
Therapy services all require management of the whole patient, including medically complex patients with multiple medical conditions. Therapy progress reports, which are required every 10 visits, involve the same assessment skills as a re-evaluation.
Other services provided by occupational therapists that have a clearly established assessment and management component and therefore should be considered for additional reimbursement through RVU increases in the CY 2021 MPFS Final Rule include:
97542 Wheelchair management (e.g., assessment, fitting, training), each 15 minutes
97755 Assistive technology assessment (e.g., to restore, augment, or compensate for existing function, optimize functional tasks, and/or maximize environmental accessibility), direct one-on-one contact, with written report, each 15 minutes
97760 Orthotic(s) management and training (including assessment and fitting when not otherwise reported), upper extremity(ies), lower extremity(ies), and/or trunk, initial orthotic(s) encounter, each 15 minutes
97761 Prosthetic(s) training, upper and/or lower extremity(ies), initial prosthetic(s) encounter, each 15 minutes
97763 Orthotic(s)/prosthetic(s) management and/or training, upper extremity(ies), lower extremity(ies), and/or trunk, subsequent orthotic(s)/prosthetic(s) encounter, each 15 minutes
I urge CMS to reconsider the distribution of payment reductions for budget neutrality and, at a minimum, grant additional RVU reimbursement consideration for the following therapy CPT codes to help offset the budget neutrality cuts: 97530, 97110, 97542, 97755, 97760, 97761, and 97763.
I have personally used Telehealth and thought it was very successful. Seeing the pandemic that the world is going through due to COVID-19 telehealth has been a wonderful experience. COVID-19 has taken a toll on the elderly. Many doctor appointments have been through telehealth it keeps them safe from have contact with others who might be carrying the virus. It helps with them not having to have someone drive them or making arrangements to get there. Telehealth with Occupational Therapy has been beneficial, you can still work the patient and still direct with therapy.
Expand Telehealth Flexibilities Permanently to Therapy Practitioners
While I appreciate the consideration CMS gave to occupational therapy, physical therapy, and speech-language pathology practitioners to perform telehealth for the duration of the COVID-19 public health emergency (PHE), I have concerns about my patients’ ongoing therapy and rehabilitation issues after the PHE ends and the waivers are revoked or expire. I ask that CMS consider longer waiver coverage while the agency considers lifting the PHE. Until there is a vaccine, COVID-19 will continue to be present in our communities and health care facilities. Further, data currently indicates that
I urge CMS to extend the therapy services telehealth waiver flexibility beyond the PHE so that beneficiaries are not left suddenly without viable and safe rehabilitation treatment options. The additional time will also allow
Add Therapy Services to the Telehealth Services List
I understand that CMS is concerned about the confusion adding therapy services to the Medicare telehealth list could cause because therapists are not Medicare-eligible telehealth providers outside of the PHE. However, the experiences of the PHE have demonstrated that therapists can effectively and efficiently provide services using audio visual technology. Our associations will continue to advocate with
Adding the above listed CPT codes to the Category III list, in combination with extending waiver flexibilities to allow therapists to perform telehealth beyond the PHE, is the best solution to ensure the best possible outcomes for Medicare beneficiaries.
Communication Technology-Based Services
I appreciate that CMS is allowing therapists to continue to bill G2061-G2063 after the end of the PHE for E-visit services. The addition to the fee schedule of G20X0 and G20X2 as permanent non-physician equivalent codes to G2010 and G2012 at the same reimbursement rate is also supported and appreciated.
III. Therapy Assistants Performing Maintenance Therapy
I thank CMS for proposing allowing occupational therapy assistants to perform maintenance therapy under the Medicare Physician Fee Schedule (MPFS). This change aligns the MPFS policy with CMS’ policy for all other settings and assures consistency and continuity of care across Medicare programs for patients receiving therapy services.
IV. Student Medical Record Documentation
I support the CMS proposed policy allowing therapists to review and verify student documentation instead of therapists having to re-document notes made by students for Medicare Part B patients. This is a significant burden reduction that will allow for better use of therapists’ time.
I would like to thank CMS for the steps taken during the PHE to ensure safe beneficiary access to Medicare services. Accordingly, I urge CMS to continue to take thoughtful and innovative steps to ensure that beneficiaries have access to medically necessary therapy services in the future. Thank you again for your consideration of the comments outlined above.
Student of Occupational Therapy
* * *
The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0088-1604
TARGETED NEWS SERVICE (founded 2004) features non-partisan ‘edited journalism’ news briefs and information for news organizations, public policy groups and individuals; as well as ‘gathered’ public policy information, including news releases, reports, speeches. For more information contact