On Friday, June 14, 2013, the Medicare Payment Advisory Commission (MedPAC) released their mandated report to Congress, Report to the Congress: Medicare and the Health Care Delivery System. This much anticipated report includes, in Chapter 9, recommendations to Congress—and indirectly to the Centers for Medicare and Medicaid Services (CMS)—for reforming therapy payment mechanisms. Below is a list of the final recommendations the Congress is asked to consider.
- Gather more clinical data in a streamlined, standardized assessment tool that includes information on functional limitations and status, patient demographics, diagnoses, medications, and surgery for all therapy types to measure the impact of therapy services.
- For long-term payment reform, use the data to develop an episode-based, bundled payment system with reimbursement influenced by a patient's functional improvement.
- Increase scrutiny of therapy services delivered in geographic areas prone to inappropriate use consistent with the Office of Inspector General recommendations. Medicare Administrative Contractors (MACs) should focus efforts on review and site visits for providers in problem areas rather than widespread review of providers in areas where there is little evidence of inappropriate use.
- Streamline manual medical review, to include notification of receipt of documents, a 10-day response time, and dedicated manual medical review sites with one or two contractors.
- Continue the 50% multiple procedure payment reduction (MPPR) for all therapy services provided on the same patient, the same day, and in the same facility or group practice.
- Improve use of diagnosis codes and automatically deny claims that use the general "V codes" as the principal diagnosis for therapy.
- Implement national guidelines and edits on the number of timed codes billed per day per beneficiary.
- Reduce the physician certification period for therapy plans of care from 90 days to 45 days.
- Permanently include hospital therapy services in the therapy cap.
- Reduce the combined speech-language pathology and physical therapy cap limits to $1,270 in 2013.
MedPAC is an independent Congressional agency tasked with advising Congress on Medicare reimbursement policy and analyzing access to care, quality of care, and other issues affecting Medicare. The Middle Class Tax Relief and Job Creation Act of 2012 mandated that MedPAC recommend payment reform for outpatient, Part B therapy services. MedPAC was required to consider the payment based on the patient's condition and to examine private sector initiatives regarding therapy services.
The June 2013 report fulfills the biannual requirement for MedPAC to advise Congress regarding Medicare payment across all services. Chapter 9, Mandated Report: Improving Medicare's payment system for outpatient therapy service, specifically addresses all therapy services: speech-language pathology, physical therapy, and occupational therapy. The recommendations are considered by Congress for future legislation regarding the therapy cap and therapy services and utilized by CMS in regulatory changes. The recommendations are not statute or policy and include the MedPAC commissioner's estimations of the implications for federal spending, patient access, quality, and health care delivery reform. Congress and CMS are not required to enact recommendations from MedPAC.
ASHA has been working with MedPAC to ensure that speech-language pathology services are appropriately recognized and addressed. The final report did not significantly vary from the public discussions, despite significant advocacy efforts on the part of ASHA and other therapy organizations. ASHA will continue to work with MedPAC, CMS, and policymakers to ensure access to medically necessary therapy services for Medicare beneficiaries.
For additional information regarding MedPAC, please contact Lisa Satterfield, ASHA's director of health care regulatory advocacy, at [email protected].