On September 6, PTPN submitted comments to CMS on the proposed 2017 Medicare fee schedule. Specifically, we commented on the following areas:
NEW EVALUATION CODES
CMS has proposed three new therapy evaluation codes to reflect three different levels of complexity, however CMS is proposing to pay them all at the same level of reimbursement in 2017. CMS then proposes to look at claims data from 2017 and make a decision in the future about how to pay for these codes. Instead, PTPN urged CMS to adopt the new evaluation codes with different reimbursement levels starting in 2017 as proposed by the APTA and AMA. If therapists are going to be required to code to specific levels of complexity, then the pricing should reflect that. Further, if that coding is going to influence reimbursement going forward, paying providers the same amount for each code will call into serious doubt the validity of the 2017 claims data, as providers generally take coding and documentation requirements more seriously when they are tied to reimbursement.
As we’ve previously reported, CMS has identified ten potentially misvalued (read over-valued) codes which are not coincidentally the most commonly used in therapy. PTPN recommended that CMS not take any action on these codes until the APTA can finish its work on these code valuations.
EXPANSION OF THE DIABETES PREVENTION PROGRAM
CMS is seeking to expand the diabetes prevention program to Medicare beneficiaries. The new Medicare Diabetes Prevention Program (MDPP) would become effective on January 1, 2018. PTPN supports the proposal that would allow existing Medicare providers and suppliers who wish to become MDPP coaches and bill for MDPP services to simply inform CMS of their intention to do so and satisfy the other enrollment requirements, which would make it easy for therapist to enroll.
PHYSICIAN SELF-REFERRAL UPDATES
CMS used the proposed rule to reiterate their previous rulemaking that while office space and equipment rental is allowed under the physician self-referral statute, in order to prevent abuse of the program, it is prohibited to use per-unit of service (aka “per-click”) compensation formulas in order to determine office space and equipment rental charges. PTPN thanked CMS for continuing to recognize the perverse incentives created by compensation arrangements between physicians and other providers that are based on volume. We also thanked CMS for recognizing that financial arrangements not only risk wasting funds, but could also limit access to more appropriate treatment options because “the medical marketplace suffers if new competitors cannot win business with superior quality, service, or price”.
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