The American Occupational Therapy Association (AOTA), Bethesda, Md, has submitted a comment letter in response to the 2010 Medicare Physician Fee Schedule and Other Part B Payment Policies for CY 2010; Proposed Rule (CMS-1413-P).
Below find some of the highlights of the letter:
As a result of the perceived problems with the sustainable growth rate (SGR) formula, the Proposed Rule would decrease professional payments under the 2010 fee schedule by 21.5 %. CMS proposed in the Rule that the Physician Practice Information Survey (PPIS) data replace the currently used SMS data in the calculation of administrative practice expense. AOTA urges CMS to follow through with its intent in the Proposed Rule to use the more accurate and up-to-date PPIS practice expense (PE) data. AOTA appreciates the effort of the American Medical Association and CMS in obtaining updated administrative cost data and including Non-Physician Practitioner practices in the survey process.
The current data that CMS uses to calculate the per-hour costs are more than ten years old for the vast majority of physicians and other professionals.
CMS chose the appropriate time to incorporate the PPIS data as 2010 is the year that the new PE methodology is fully transitioned and utilizing the most current data to reflect practice cost is key to ensuring that the methodology is fair and accurate. It is imperative that Medicare use the most current and accurate data in order to determine practice expense payments for Part B providers.
AOTA continues to oppose the underlying policy to apply a financial cap on therapy services available to beneficiaries who need them. AOTA asserts that the therapy cap is an arbitrary and inappropriate solution to assure correct utilization of and payment for therapy services. CMS has instituted many other means of ensuring appropriate utilization of therapy services.
While AOTA agrees that the current law limits occupational therapy services from being provided under the Medicare telehealth services program, AOTA is currently working to change the law governing telehealth services. AOTA is supporting telehealth legislation currently pending in Congress that would authorize occupational therapy services to be provided via telehealth. In addition, AOTA has signed a petition as part of a coalition of like-minded organizations spearheaded by the American Telemedicine Association, which urges Congress to expand Medicare’s limited coverage for telehealth services. AOTA asserts that such a change would greatly benefit the Medicare program from a cost savings perspective because the occupational therapy services can be provided via telecommunication technology.
The comments also cover Physician Quality Reporting Initiative (PQRI), and Payment and Coverage Improvements for Patients with Chronic Obstructive Pulmonary Disease and Other Conditions—Cardiac Rehabilitation Services.
To read the letter in its entirety, AOTA members may click here.
[Source: AOTA]
