A study funded by the Centers for Medicare and Medicaid Services (CMS) has named ASHA's National Outcomes Measurement System (NOMS) as one of four patient assessment tools suitable for CMS testing in the development of Medicare Part B outpatient payment policies. This recommendation was part of the "Outpatient Therapy Services Pilot Report 2006," recently released by Computer Science Corporation (CSC), a CMS contractor.
The study was designed to investigate alternatives to the current therapy cap system. These alternatives would identify beneficiaries' need for and the effectiveness of outpatient therapy services. The study echoes a June 2006 Medicare Payment Advisory Commission report that also recommends NOMS for CMS consideration.
CSC assessed outpatient therapy patient assessment tools currently used by practitioners, and recommended which could provide CMS with more accurate data on a beneficiary's need for services. The report also recommended pilot activities that CMS could implement immediately, not only to refine current payment policies but also to begin development of long-term solutions to the therapy caps.
NOMS, developed exclusively for speech-language pathology services, is the only CSC-recommended patient assessment tool that contains a dysphagia assessment. Swallowing disorders represent nearly half of the Medicare outpatient speech-language pathology population.
In its review of current outpatient assessment tools, CSC found that while there are national and local coverage and billing policies in place, CMS has no mechanism other than manual medical review to identify if treatment services billed to Medicare are either medically necessary or effective. The report also identified measurements-not available on current claims-that would indicate which patients need treatment. These measures include an illness severity score, previous physical function measurement, health-related quality of life score, mental function measurement, and social support indicator and patient classification as determined by a patient assessment instrument.
CSC's review of current patient assessment tools related to treatment services found four instruments to be clinically and scientifically appropriate and technically capable of being tested by CMS to gather more patient data:
- ASHA's NOMS
- Outpatient Physical Therapy Improvement in Movement Assessment Log (OPTIMAL)
- Patient Inquiry® from Focus on Therapeutic Outcomes (FOTO)
- Activity Measure for Post-Acute Care (AM-PAC)
Additional information on NOMS can be found on ASHA's website.
Proposed Pilot Project
The study proposes that CMS test the four patient assessment tools to determine if the instruments can be modified for CMS use and if they could be used as part of an alternative payment system. Data collected from this pilot project could be used to develop more widespread demonstration projects and, ultimately, a required outpatient therapy assessment tool. Results could also serve to support changes to existing payment policies, such as the therapy cap exceptions process.
CSC proposes that the assessment tool developers, such as ASHA, would recruit providers to participate in the pilot projects and would serve as the principal point of contact between study participants and Medicare. Participants would be required to submit completed patient assessment instrument data at the beginning and end of an episode and possibly in the event of significant changes in patient status.
CSC also suggests that CMS require all pilot project providers and suppliers obtain and submit data with a clinician National Provider Identifier (NPI). Such data could allow CMS to compare the similar services offered by various providers.
To encourage participation in the pilot program, CSC recommends using various incentives, including exemption from the therapy caps, exemption from physician certification requirements, and—most significant for speech-language pathologists—SLP supplier status to allow private practice billing under individual provider numbers.
The pilot studies, if implemented, are a first step in helping CMS identify alternative payment policies to replace the therapy caps. CMS needs to collect significantly more data on a beneficiary's need for treatment to promote more effective payment policies. Although CMS is not required to act on the CSC's recommendations, ASHA is actively working with both CMS leadership and Congress to advance the recommendations contained in the report.