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CMS' Final Rule Packs a Punch

CMS' vision for the future of America's health care system came into focus with the release of the Final Rule yesterday.
The 2000+ page document outlined several important changes in support of maximizing patient care time; broadening access to services; and incentivizing physicians to work at the top of their license.
New initiatives focused on boosting reimbursement rates for services requiring more face-to-face patient time and reducing red tape (that will save an estimated 2.3 million administrative hours per year) include such changes as:
  • Expansion of telehealth services for physicians and nurse practitioners. For example, the Final Rule supports access to telehealth services for one visit every 14 days (instead of the proposed 30 day limit).
  • Expansion in telehealth services for therapy services (In fact, nine new codes added for Physical and Occupational Therapy with an important clarification: Telehealth rules/reimbursement is NOT applicable when a beneficiary and clinician are in the same location.)
  • "Maintenance Therapy" (i.e.: ongoing care after a therapy program is established) can be provided by therapy assistants under a supervising registered physical therapist or occupation therapist.
  • Documentation practices for clinicians who directly bill Medicare (inclusive of speech-language pathologists, physical therapists and occupational therapists) will change in order to reduce duplicative documentation. Specifically, rather than re-document information already entered by other members of the clinical team, therapists may simply 'review and verify.'
HealthPRO Heritage's Statement RE: The Final Rule
HealthPRO Heritage recognizes CMS' Final Rule admirably supports more accessible, affordable services and strives to promote innovation, higher quality care, and patient empowerment. However, practitioners across the continuum, especially rehab providers in Senior Living, Outpatient, Medicare Part B at Home programs, and Skilled Nursing, will take a significant hit!
CMS intends to follow through on proposed deep cuts (~9%) to physical therapy and occupational therapy service codes. This significant change in reimbursement comes at an inopportune time. Many industry leaders argue the need to preserve – and perhaps even to prioritize – rehab services for seniors suffering the brunt of the public health emergency due to soaring rates of physical, functional and psychological issues stemming from isolation, deconditioning and depression caused by the pandemic.
ACTION REQUESTED: Current funding will expire on December 11, leaving only 10 days for possible congressional action to reverse these cuts. This means we need to lock down congressional support for a fix now! Several senators, including Susan Collins (R-ME) and Steve Daines (R-MT), have written to Senate leadership on behalf of rehab care providers, but more action is needed! On behalf of seniors who require robust specialty services, especially in outpatient, through Home Health and senior living/nursing facility settings,  please take action TODAY!
Moving Forward...
HealthPRO Heritage will continue to review details and nuances outlined in yesterday's announcement, and communicate our interpretation + guidance. In the interim, we invite you to reflect thoughtfully on the following Questions Worth Asking to think-forward about how to navigate the impact of these changes on your community and your residents:
  • If physicians visit care centers less frequently (opting for more telehealth visits), how will your teams continue to collaborate on critical information exchange to prevent hospitalizations? To verify active medical diagnosis? 
  • What is an optimal approach to partnering with physicians and nurse practitioners now that they are incentivized to see patients in their offices versus seeing patients on-site within communities?
  • Is your team well-aligned with CMS' intention to harness innovation in care delivery? For example, how can you optimize partnerships with your referring/consulting physicians?
  • How will you leverage expansion of telehealth services to advance staffing solutions? To optimize clinical programming?
HealthPRO Heritage is now accepting Requests for Proposals for 2021 & Beyond! Review details here.