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 AHCA/NCAL Seeks Improvements to CMS Proposed Medicare Part B Rule

In comments to the Centers for Medicare & Medicaid Services (CMS), the American Health Care Association/National Center for Assisted Living (AHCA/NCAL) on Sept. 10 asked the agency to make changes to its proposed calendar year 2019 Medicare Part B Physician Fee Schedule covering such areas as therapy services and communication technology-based services.

These issues, and others, are important to AHCA/NCAL’s provider members because Medicare Part B pays for physician services; physical, occupational, and speech therapy; some equipment and supplies; and some drugs and biologics furnished to outpatients.

Part B also pays skilled nursing facilities (SNFs) for therapies for residents that are not otherwise eligible for Part A coverage, furnished either directly or under arrangement under consolidated billing provisions, according to the association.

“The central theme of our comments and recommendations was to encourage CMS to continue to refine their proposed policies to assure appropriate access to necessary physician and therapy services for residents in our member SNF and assisted living residences,” Dan Ciolek, AHCA/NCAL associate vice president of therapy advocacy, tells Provider.

He also says the association believes its recommended improvements “will reduce provider burden while increasing available options to improve quality of care, including reducing rehospitalization rates.”

In a summary of the comments to CMS on its July 27 proposed rule, AHCA/NCAL said there were five key topics it wanted to address.

The first is therapy services. CMS proposed several policies related to coding and payment for therapy assistants that are required as part of the “pay-for’s” for the therapy cap repeal legislation passed earlier this year in the Bipartisan Budget Act of 2018. AHCA/NCAL recommended improvements to the definitions of key new terminology to make the policy clearer, and to protect access for patients with more complex needs.

In a separate therapy issue, AHCA/NCAL said it backed a provision in the proposal to eliminate burdensome and ineffective reporting requirements related to function.

For the second main comment topic, AHCA/NCAL said CMS’ plan contains new telecommunication-based codes that fall outside of Medicare telehealth legislation limitations. CMS also discussed potential changes to existing telehealth policies in its proposed rule.

In its comments, AHCA/NCAL advocated for more opportunities to increase communication technology-based services for SNF residents, and to reduce SNF telehealth limitations so that they are consistent with other inpatient rehabilitation facility and long term care hospital post-acute care settings.

For the third issue, physician evaluation and management (E&M) code policy changes, CMS proposed cutting some of the documentation burden on office-based services and also collapsing payment rates for the highest-intensity E&M services. These affect geriatricians and other specialties that commonly care for elderly SNF residents and those with disabilities.

While not directly impacting physician services furnished in the SNF, AHCA/NCAL told CMS that the policy could discourage physicians from working with this growing population, hurting the available SNF physician workforce. 

The fourth area is updates to the Part B fee-schedule-based Quality Reporting Program. Here, CMS in its proposal did not recognize facility-based Part B therapy services/therapists (including SNFs) as being eligible for the Part B merit-based incentive payment system and alternative payment model fee schedule-based incentive programs. This is despite the fact that physical and occupational therapists in private practice will become eligible if the rule is finalized.

AHCA/NCAL cited concerns that this oversight would create unbalanced quality and payment systems, as nearly two-thirds of therapy providers (including SNF) would remain ineligible for the quality incentives.

Lastly is the area of a Request for Information on interoperability. AHCA/NCAL said this is the same request that it submitted comments for in the recent SNF Proposed Payment System fiscal year 2019 Notice of Proposed Rulemaking. Again, the association said it reiterated and updated previously submitted comments that cited funding concerns and offered practical suggestions to encourage increased operability without adding unnecessary administrative burdens.

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