Continued, Disruptive Medicare Cuts
The Centers for Medicare & Medicaid Services (CMS) have proposed another set of deep, across-the-board payment cuts to physical, occupational, and speech therapy in the Proposed Physician Fee Schedule (PFS) Rule for CY2023.
The proposed rule, released July 7, includes a 4.5 percent cut to providers in 2023, which signals the sector is projected to experience cuts of approximately 9 percent between 2020 and 2024. Medicare’s proposed payment reductions are a result of the expiration of the 3.0 percent increase in the MPFS conversation factor for CY 2022.
This cut comes on the heels of a series of payment reductions by CMS in recent years.
In the Physician Fee Schedule (PFS) Rule for CY2022, CMS finalized a 3.75 percent cut to providers in 2022 and a troubling 15 percent cut for services provided by physical and occupational therapy assistants. A broad coalition of lawmakers and stakeholders came together to oppose and support longer-term reforms to the fee schedule, and fortunately, lawmakers in Congress took action.
In December 2021, Congress passed the Protecting Medicare and American Farmers from Sequester Cuts Act (S. 610), which includes a partial extension of the Medicare conversion factor payment increase in 2022 and sequester relief for another six months. However, that temporary sequester relief ended on June 30.
While we commend this legislation and the efforts of lawmakers to protect Medicare patients and specialty care providers in the coming year, we know that the relief is temporary.
Continued cuts to physical, occupational, and speech therapy services destabilize the ability of vulnerable seniors to access the vital care they need. APTQI will again need the help of Congress to combat Medicare’s repeated cuts to specialty care services or risk further limiting senior access and choice.
Physical & Occupational
Assistant Therapy Cuts
Physical and occupational therapist assistants (PTAs/OTAs) are an essential part of the therapy profession, providing direct patient care services to patients under the guidance and supervision of licensed physical therapists.
Despite the incredible value therapy assistants offer to patients, the Centers for Medicare & Medicaid Services (CMS) imposed a 15% Medicare payment cut on the direct patient care services provided by PTAs and OTAs starting January 1st.
This is in addition to a number of Medicare cuts to therapy services in recent years. This additional 15% cut will only further restrict the ability of the profession to meet patients’ pain management and recovery needs using the safest, most cost-effective care path.
If these cuts remain, our patients, especially those living in rural and underserved areas, may face new barriers to care when trying to access the treatment they need.
To protect Medicare beneficiaries’ access to care, Representatives Bobby Rush (D-IL) and Jason Smith (R-MO) have introduced the Stabilizing Medicare Access to Rehabilitation and Therapy (SMART) Act (H.R. 5536).
Specifically, the bill would:
- Delay the implementation of payment cuts until January 1, 2023, to allow providers more time to prepare.
- Permanently prevent the 15% Medicare cuts to services provided by PTAs and OTAs in rural and medically underserved areas.
- Reduce requirements for direct supervision of therapy assistants in private practice settings – shifting from direct to general supervision in states with licensure laws that allow for general supervision – helping to ensure continued patient access and giving small therapy practices more flexibility.
In addition to in-person visits, physical therapy services can be effectively delivered via videoconference or phone call, allowing therapy specialists to provide high-quality care to patients.
Telehealth can be effective in helping patients overcome many treatment access issues including distance, a lack of nearby specialists, and/or impaired mobility.
Physical therapists currently use telehealth in a variety of ways, including:
- Screening the patient’s home for fall hazards– thereby helping to reduce the risk of fall-related injuries in the home;
- Remotely observing and monitoring patient compliance with their home exercise program and providing verbal and visual feedback and instructions;
- Providing consultative services to other healthcare providers to coordinate care; and,
- Performing screening and assessment services remotely, saving patients a trip to the clinic for therapy that can be performed in the home
During the COVID-19 pandemic, telehealth services have been critical to enabling continued patient access to physical therapy.
By providing physical therapy services via telehealth, therapists have ensured seniors and other at-risk patient populations can manage their pain, regain strength, and enhance mobility — all while minimizing the risk of COVID-19 transmission, preventing costly hospitalizations, and reducing unnecessary strain on the healthcare system during the public health emergency (PHE)
In response to the PHE, the Centers for Medicare & Medicaid Services (CMS) increase access to physical therapy by reimbursing providers for telehealth-based services delivered to Medicare beneficiaries. However, this expansion is not permanent
The Expanded Telehealth Access Act of 2021 (H.R. 2168/S. 3193) would make permanent the temporary policy that allows physical therapists and physical therapist assistants to deliver and bill for services provided via telehealth under Medicare. This bipartisan legislation specifically includes physical therapists and physical therapist assistants.
APTQI urges Congress to pass this important legislation so the physical therapy community can continue their important work of caring for seniors in need despite their location.
Current Medicare regulations impose significant burdens on physical therapists. When patients require physical therapy, restrictive rules require physical therapists (PTs) to navigate a lengthy, cumbersome process to be reimbursed for the medically-necessary treatments they provide.
When serving Medicare beneficiaries, physical therapists typically face a frustrating process that forces them to spend vast amounts of time filing paperwork, instead of focusing on what they do best: treating patients.
After Medicare patients, the vast majority of whom already have a referral from their doctors – make an appointment for physical therapy, the physical therapist creates a specialized plan of care tailored to the patient’s medical needs, which then requires the referring provider’s signature - even though they have already referred the patient. Physical therapists then must devote a vast amount of time and resources to following up with referring providers and secure the redundant signatures or their services will not be billable.
The regulatory requirements in place now are redundant and undercut the authority of physicians and other referring providers to recommend appropriate care for Medicare beneficiaries. APTQI is committed to working collaboratively with the Centers for Medicare & Medicaid Services (CMS) to reform Medicare requirements under the Physician Fee Schedule (PFS) to support the timely delivery of and reimbursement for PT services.
The ongoing opioid crisis in the U.S. has led to a growing realization that current pain management strategies have to change. Prescription opioids – which mask, rather than treat the underlying cause of pain – have contributed to widespread opioid misuse and addiction in communities throughout the U.S.
In order to help combat opioid misuse, it is necessary to adopt new approaches to pain management. Physical therapy is a clinically proven, cost-effective pain management alternative that should be leveraged earlier and more often to prevent opioid misuse and addiction.
Promoting access to physical therapy is critical because, unlike, prescription opioids, PT prevents and treats the underlying cause of pain. Research shows the efficacy of physical therapist interventions in preventing, minimizing, and, in some cases, eliminating pain.
In its Guideline for Prescribing Opioids for Chronic Pain, the Centers for Disease Control and Prevention (CDC) recommends physical therapy as an alternative to opioids for the treatment of chronic pain. The CDC notes PT is especially effective at reducing pain and improving function in cases of low back pain, fibromyalgia, and hip and knee osteoarthritis.
The United States is currently in the middle of a national shortage of physical therapists and physical therapy professionals. Estimates show that by 2025, an additional 27,000 PTs will be needed to meet demand. This problem is particularly acute in rural areas because many physical therapists are concentrated in major metropolitan areas. APTQI members are eager to invest in underserved communities if they had the resources to recruit more PTs and expand care.
To address this shortage, Senator Jon Tester (D-MT), Senator Roger Wicker (R-MI), Rep. Diana DeGette (D-CO), and Rep. Kelly Armstrong (R-ND) introduced the Physical Therapist Workforce and Patient Access Act (S. 2676/H.R. 3759), which would enable physical therapists to participate in the National Health Service Corps student loan repayment program.
In an attempt to alleviate shortages of medical professionals around the country, the National Health Service Corps provides student loan relief to medical professionals who commit to serve in a medically underserved or designated health care professional shortage area (HPSA). This makes it difficult for physical therapists to deliver services and open centers in critically underserved markets. Under this legislation, the NHSC loan repayment program would allow physical or occupational therapists to participate, thereby improving access to physical therapists in HPSA areas where companies are hoping to establish community-based centers.