On October 2–4, join ASHT for Virtual Capitol Hill Day 2019. The event will be held in conjunction with the ASHT Annual Meeting in Washington, D.C.
Occupational and physical therapy advocates across the country will speak with their Congressional legislators about federal policies that impact access to rehabilitation services and highlight the critical role hand therapists play in helping patients maximize function and manage acute and chronic upper extremity pain.
With more than 100 newly elected representatives and senators, the 116th Congress needs to hear directly from hand therapists like you as they consider key legislation and policy issues impacting the delivery of hand and upper extremity therapy services
Please reach your Congressperson and send the following email sample!!!!!!! We need your help!!!!!
1.Get Your Congressperson’s Email:
Log into the ASHT website using your member account. Navigate to the Legislative Action Center via the
ASHT home page, scroll to the bottom and click the featured block. Your congressional representatives will be
displayed on the right side of the page, including contact information. If you do not have an ASHT account, google your Congressperson and send them the following email:
2. Construct Your email
Dear [Congressperson or Senator],
As a constituent and hand therapist, I am writing to share my concerns regarding the policies advanced in the Medicare Physician Fee Schedule Proposed Rule for CY2020.
The profession of hand therapy is comprised of licensed occupational and physical therapists who specialize in the treatment and rehabilitation of the upper extremity. We help clients maximize function by providing evidence-based rehabilitation interventions for those with diseases, injuries or conditions resulting in upper extremity dysfunction. Importantly, we also play a key role in helping clients manage chronic pain, which serves as a vital alternative to the use of opioids.
As a member of the American Society of Hand Therapists, whose membership includes occupational,
and physical therapists, assistants, researchers, and students, I appreciate the opportunity to share my
concerns regarding these policy proposals and their potential impact on the hand therapy profession and
on Medicare beneficiaries’ ability to access needed therapy services.
As our profession prepares for the upcoming change, we want to make you aware of our concerns
surrounding CMS’ proposals on the following policies:
1. In its CY2020 MPFS Proposed rule, CMS is proposing payment changes to the physician fee schedule’s evaluation and management (E/M) codes. The proposed changes are significant, as E/M visits represent a large percentage of allowable physician fee schedule services, and would result in reimbursement cuts elsewhere, including therapy services. CMS’s proposal could result in reimbursement cuts of up to 8% for therapy services.
2. Separately, CMS proposed that, for outpatient therapy services, an explanation, in the treatment notes, must accompany each claim in order to justify why a modifier was applied or not applied. The documentation requirements resulting from this proposal would be time-consuming and overly burdensome, particularly for hand therapy practices that utilize assistants with far less frequency.
3. As a result of the Bipartisan Budget Act of 2018 (Pub. L. 115-123), outpatient therapy providers will be required, beginning January 2020, to use a modifier to indicate when services are provided in whole or in part by an occupational therapy assistant (OTA) or physical therapist assistant (PTA). Those services will then be subject to a 15% reduction in reimbursement. CMS also proposed that services will be considered to have been ‘furnished in all or part by an OTA or PTA’ when more than 10% of the total service time is furnished in whole or part by the assistant (OTA/PTA). The use of assistants is often deployed to ensure safe and effective team-based care. This proposal disincentivizes safe and effective team-based care. I would suggest, instead, that the standard be applied only when services are provided independently by an OTA/PTA.
CMS also proposed that services will be considered to have been ‘furnished in all or part by an OTA or
PTA’ when more than 10% of the total service time is furnished in whole or part by the assistant (OTA/
PTA). The use of assistants is often deployed to ensure safe and effective team-based care. This proposal disincentivizes safe and effective team-based care. I would suggest, instead, that the standard be applied only when services are provided independently by an OTA/PTA.
Reimbursement cuts of that magnitude would have both acute and long-term effects on the hand therapy workforce. CMS should strongly reconsider the proposed E/M changes due to the unintended consequences of the proposed changes.
Ultimately, I believe these policy proposals will have a negative impact on access and delivery of therapy
services to Medicare beneficiaries.
I appreciate the opportunity to provide feedback on the Proposed Physicians’ Fee Schedule Rule.