APTQI Urges CMS to Revise the Proposed Physical Therapy Provisions in Physician Fee Schedule (PFS) Rule for CY 2020

Proposed across-the-board 8% cut to PT services would create market instability and hinder patient access to therapy services to reduce opioid use and prevent senior falls

WASHINGTON –– The Alliance for Physical Therapy Quality and Innovation (APTQI) today submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) urging them to make a series of revisions to a recently proposed rule that threatens to undermine patient access to vital physical therapy services.

If implemented in its current form, CMS’ proposed Physician Fee Schedule (PFS) rule for CY 2020 would usher in across-the-board 8 percent cuts to physical therapy services starting in 2021. This proposed reduction would exacerbate the effects of previous cuts implemented in recent years, including a 2011 multiple procedure payment (MPPR) reduction, which was increased in 2013, as well as the reduction of two common procedural codes used by physical therapists, Therapeutic Exercise and Manual Therapy, in 2018.

In the comment letter, APTQI urges CMS to adopt a number of changes to the final rule, including:

• Reverse the Proposed 8% reduction for Physical/Occupational Therapy for CY 2021. APTQI expresses its opposition to value redistributions for physical and occupational therapy included in the proposed rule. While recognizing that CMS must be budget neutral when implementing any increase in work values for the office/outpatient E/M codes, APTQI asserted that the potential impact of the proposed cuts would significantly stifle patient access to vital PT services. APTQI also framed the proposed cuts into the wider context of payment reductions which have occurred in recent years, noting that such policies threaten to undermine the nation’s response to the opioid crisis and preventing seniors from falling in their homes, which data show increase healthcare costs and lead to increased mortality rates.

• Alter Requirements to Assign the CQ/CO Modifiers When a Therapist Performs a Service. APTQI urges CMS to change a requirement that a therapist must assign the CQ/CO Modifier, and the 15% decrease in reimbursement that goes along with it, when a physical therapist assistant (PTA) participates concurrently with a physical therapist for greater than 10 percent of the total time spent in the delivery of treatment to a patient. Noting that delivering PT services to patients sometimes necessitates the participation of both a physical therapist and a PTA, APTQI urges CMS not to require the CQ/CO modifier when the patient’s condition necessitates the presence of a therapist and an assistant at the same time for optimal treatment and patient safety.

• Implement Changes to Documentation Requirements Surrounding Application of the CQ/CO Modifiers.
  APTQI expressed opposition to a proposed requirement that physical therapists “explain, via a short phrase or statement, the application or non-application of the CQ/CO modifier for each service furnished that day.” Noting the new and unnecessary administrative burden this policy would impose, APTQI contended that the requirement would do nothing to improve clinical quality or patient care and should thus be removed from the final rule.

• Adopt the HCPAC-Recommended work RVUs for the new dry needling CPT codes. APTQI urges CMS to reverse its proposal to reduce the work RVUs from the levels recommended by HCPAC since they are based on a flawed rationale. Specifically, APTQI urges CMS to adopt the HCPAC-recommended work RVU of .45 for CPT code 205X1 and to update the 205X2 code to reflect the higher intensity and different level of skills required for the procedure.

• Develop MIPS Value Pathways with an Appropriate Timeline and Provider Input. APTQI expresses its concern that developing and implementing MVPs by 2021 is not feasible. Cautioning that a complete overhaul of the MIPS program would severely disrupt participating clinicians and other admirative and support staff, APTQI urges CMS, among other things, to delay implementation of MVPs and increase cooperation with providers to ensure a smooth transition.

“While APTQI supports CMS’ commitment to improve patient treatment outcomes and lower the cost of care for Medicare beneficiaries, we also have deep concerns about the significant reimbursement reductions included in this proposed rule,” said Nikesh Patel, PT, DPT, Executive Director of APTQI. “As the United States continues to confront a series of health challenges, including the opioid crisis and the epidemic of elderly Americans falling in their homes, patient access to physical therapy services must be fortified, not eroded.”

“We appreciate the opportunity to comment on the Proposed Rule and urge CMS to take action to protect physical therapists and the patients who depend on them,” concluded Patel.

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