2020 Rehab Industry Preview

September 17, 2019

Hosted By:

Nick Austin

Hello everyone and welcome to today’s webinar the 2020 rehab industry preview. My name is Nicholas and I’m the director of product management here at hands on technology and I’m happy that you were all able to join us today for what I’m sure will be a riveting update on the rehab industry. Most of you have probably already heard a little bit on most of what we will discuss today

Who bought I am hoping that we can go into a few details that you might still be unclear on and add a little bit of clarity there.  Then we’ll move into some subjects that you thought you knew all about. And I had a little bit of CMS infused fogginess to the picture. We will have plenty of time for questions at the end will do my absolute best to answer

So please make sure to get those questions submitted as they come to mind. So let’s go ahead and get started. So what we’ll talk about today is first the 2019. Oops. I know this will only impact a subset of you that are submitting on my lips, but I figured it was important enough to cover it still then we will go into 2020 MEPS and the changes that we are currently expecting for the program and it’s sophomore year

If you are somebody who was considering participating in 2019, but ended up not and are still considering for 2020. It will be important for you to note those changes. So they will then move on to the big topic for today which are the PTA and OT a modifiers. You’ve probably heard about a bit about the subject and we’ll take this opportunity to go into what we currently know and what TheraOffice is planning before the end of the year

Finally, we’ll quickly touch base on someone 2020 CPT code changes that might be impacting some of you out there. Before we get into any of the details. I do have to include this disclaimer slide majority of the information. We will be discussing today is based on the 2020 proposed physician fee schedule is very important that not all of this is taken as gospel changes are possible and in some areas probable by the time the final rule is released

The proposed rule came out in Late July and we anticipate the final rule being released sometime around November though. It is getting harder harder to predict CMS has released timeline while this information is not based on the final rule. It is still very valuable to get a heads up on what could potentially be coming

That is the purpose of today’s webinar. Make sure that you’re paying attention to your therapist news panel and newsletters is will make sure to let you know of any important changes made that will impact your clinic.  So for the current myths reporting clinics out there the first submission period for 2019 is rapidly approaching this will begin on January 1st, 2012

If you are registered customer, this means you will be expecting a final consultation at the beginning of the year to confirm the results finalized the Improvement activity at a stations and then get the data submitted to CMS. We’re going to go a little bit more in depth on the Improvement activities on the next slide

And for those who are submitting claims on their own for mips. Remember that it is important to sign up at QP P Dot cms.gov and get your improvement activity attestation submitted. Again, that is only for the claims-based submitters. TheraOffice will not be involved in that process in any way. If you are submitting your mips data for claims, so make sure that you take that extra step

So for any mips clinics, we’ve talked in the past about how improving activities are simple a test stations that are made based on activities your clinic participates in over a 90-day period the good news is that with these with this being a brand new category. There is a lot of overlap between this and the quality measures that you are already reporting

We found three specific examples that about 95% of our midst reporting customers would also satisfy. The requirements on the first is the activity called promote use of patient reported outcomes. If you’re a photo user great, you satisfy this activity you do not use photo but you’d have some function by well those still count as patient-reported outcomes

If you do it all by a paper that even works to Patient reported outcomes are not a given in the healthcare industry, but in TT, they kind of are if you don’t attest your you don’t test your patience with anything you probably are doing so well in the quality category either. So the next one that we see here is the implementation of fall screening and assessment programs

And most of our clinics are already doing this on measures 154 and 155. We definitely recommend utilizing this overlap to your advantage. The third measure wasn’t recommended by a PTA in their initial set. So I went ahead and included the full description provided by qpp. The activity is called

Implementation of practices processes for developing regular individual care plans the full description States implementation of practices processes including a discussion on care to develop regularly updated individual care plans for at-risk patients that are shared with the beneficiary or caregiver individual care plans should include a consideration of a patient’s goals and priorities as well as desired outcomes of care

I would be surprised if there was a PT alive that wasn’t comfortable listing this as a regular. All this being said we still do recommend reviewing the entire list of a hundred eighteen available Improvement activities on Q PP Dot cms.gov and picking the most appropriate ones for your clinic. This is especially true for anyone that is not currently reporting on Falls as you will need need to find a third activity that fits with what you’re currently doing or what you hope to do in the last 90 day period that’s available

Alright, so looking ahead to 20-ton 20. What are the changes that are coming from apes first off. We have an increase on the data completeness threshold from 60% to 70% This will mean less time to decide on whether or not you’re participating in mips for the 2020 performance here.  Last year our registry signup deadline was set to the end of March this coming year

It will be set to the end of February. The next change is the minimum mips score threshold was moved from 30 to 45. This means that will be harder to avoid the penalty this year though full participation should still get you there for the 2019 year. We found that if you were a small practice facing a penalty and didn’t have enough data to meet the data completeness threshold with a minimum score some bonuses

And full Improvement activity at the station’s you can still avoid a penalty that will not be the case in 2020. If you are required you’re going to need to participate a full level or facing even worst penalty of up to nine percent payment reduction.  As of 2020 the penalty is moving from 7% to 9%

So again, make sure to be utilizing that participation lookup tool on qpp that’s cms.gov and know your status once it has been updated with the 2020 values. The next big change is that the pain assessment measure is most likely getting dropped one less measure means we need to find Space to make it up elsewhere, which we’ll talk about in the next slide overall

The message of these changes is kind of what we expected. More data required with better scores required to avoid a larger penalty.  With that pain assessment measure getting removed. We will need to replace it for non-photo non diabetes reporting clinics to still continue to report the required six measures

The good news is that there are also proposing adding a third Falls measure. This would be a perfect tie-in as you’re already probably assessing your patients Falls risk. We’ll be looking to get this into the software before the end of the year, but will obviously depend on what the final rule brings

There is also a tobacco measure that shows some promise with the right changes. Should we need to explore that option? Also in quarter for will be looking to add a way for you to make your at his stations for improvement activities right within TheraOffice. Should you forget you’ll make sure to give you that reminder during your final consultation call mentioned earlier

All right. So now it’s time for the PTA OT a modifier modifier changes that I’m sure many of you are wondering about real quickly. I wanted to touch base and why we are where we are with these modifiers. Back when the financial cap was repealed for patients. So interestingly enough not for providers

It was done with the compromise that there would be a cut elsewhere ptas note here is were the ones hit incurring a 15 percent payment reduction that is currently slated to start in 2020 or 2022. Sorry 2022 is when that payment reduction looks to be starting for pts. And OTS. This data is important to remember

Even though modifiers going into effect next year again those cuts. They’re not coming until 2022. Should they hold up for them to make these Cuts they needed better visibility on what services were actually being provided by ptas and OTAs. This leads us to the PT aota modifiers that again will go into effect January first 2020 should the current proposed rule

Hold up through to the final rule. The CQ & Co modifiers are to be used on Medicare claims in conjunction with the GP and Geo modifiers. They signal to the payer that the services furnished in whole or in part by physical therapy assistant or occupational therapy assistant, the important thing to note with these modifiers is that they used a de minimis standard of the modifier being required when the services furnished

By a PT aota for greater than 10% of the total time. This is where things can get a little bit tricky.  In the proposed rule CMS provides two methods of determining whether the de minimis standard has been met. I’m going to go through the same scenario using both methods and then we can talk about the results

Okay. So in this scenario, you have 15 minutes of therapeutic exercise performed the PT treated the patience for 13 of those minutes the PTA treated the patient for two of those minutes. The first method is to Simply take the PTA minutes and divide by the total minutes rounded. This gives me a value of 13% the de minimis standard of ten percent means that everything 11 percent or greater

Would require the PTA modifier in this example using this method the modifier is required because 13 percent greater than 11% here. You will see the second method same scenario to determine the de minimis standard take the total treatment time and multiply it by point one. To get 10% of the total treatment time as they do not work in seconds

They then asked you to round the de minimis standard up to 2. This means that the threshold to pass that standard is actually one plus that amount or three minutes using this methodology. The PTA modifier is not required in this example. No, there is no typos here each method produces different results

The examples are pulled directly from the proposed rule.  To say the very least. This is a little bit confusing and do not know why CMS would propose two methods for making calculation that produce different results and will eventually impact reimbursement at this time. My assumption is that they settle in on a single method by the time the final rule is proposed

Like I mentioned previously it is critical to keep paying attention becomes some things will probably change by the time the final rule is out there and even if this doesn’t change know that. It won’t impact reimbursement for the next two years. They’re essentially trying to create the Baseline Within These first two years

So if there’s a problem with differing calculations, they might be a factor that into their trial period we do anticipate one method being utilized by the time this actually impacts reimbursement. No, we’re unfortunately not done yet on the modifiers. There is also a small documentation requirement to add to treatment notes an explanation by a short phrase or statement the application or non application of the CQC o modifier for each service furnished that day you will see here the examples provided by CMS in the proposed rule

Applied holy finished applied with the actual percentage not applied with it being less than the standard not applicable not applicable because of no PT aota the good news on these changes is that they never specified that the explanation that unique patient patient that they’re even be an attempt of next explanation being unique luckily for all in attendance today using the EHR that will be looking to handle this redundant description

So here’s what we have planned before the end of the year modifiers as always this will sit in our design phase until the final rule gets released. We’re know that we will move fast to get you an update and train you on it before the new year to make sure you’re in compliance with the changes

First we’ll add a column to treatments for assistant minutes determination of whether or not the modifier is required will be based on those minutes plus the normal minutes. The combination of the two will be used for all suggest charges purposes. We also be adding a modifier justification column to the charges inserting predefined phrases based on the charge scenario

All of us will be controlled through an insurance is setting so if we do see Commercial Insurance has adopted changes. Well, we will be able to include those insurances know that we will be handing the calculations for you will be handling the descriptions for you. But the thing you will need to handle

Is knowing how many minutes were performed by the PTA compared to the PT? Unfortunately, we can’t help out at much on that area. So know that that part will be on you guys to know how much time that PTA is spending on the treatment in a split scenario obviously in all PT scenarios. There’s no problem in all PTA scenarios

There’s no problem. Just that one scenario of a PTA and a PT working as a team that you’re going to need to use need to know what those minute splits are. Okay. So the next three slides are few the CPT code changes that will also be going into effect January first 2020 first deleted CPT codes for nine zero nine one one nine five, eight three one nine five eight

Three two, eight three three three four and nine. Seven one two, seven. If you utilize any of these CPT codes do not immediately rush to delete them from your system as of January first 2020. They will no longer be usable. But until the end of the are there perfectly acceptable. The codes being added consists of some replacements for those previously deleted codes first to needling codes and then to biofeedback codes

Whereas now splitting based on whether or not it was the initial 15 minutes or the additional 15 minutes beyond the first

And then we’ll see the same concept here for therapeutic interventions that focus on cognitive function with the additions of nine. Seven. One two nine and nine seven one three zero to replace the nine. Seven one two, seven code. Okay. So these CPT code changes might not impact everybody, but for some it will we will not be making any customer wide changes on these codes

We do this typically for diagnosis codes and CBD checks though, not with CPT codes directly because there are some customer defined entries that we do not want to change automatically if you are impacted by these code changes. Make sure to set a reminder for yourself to on January 1st, 2020 or January 2nd to delete out the old codes and add in the new ones

This can be done for both on-site and web customers by going to manage and then CPT codes from within TheraOffice. All right. So, thank you again to everyone in attendance for today’s webinar. We hope you found the information valuable and not too confusing even when it kind of was going to now open it up for questions, and I will do my best to get them answered today

We’ve already received a few so I’m just going to take a few minutes to go through them now. But thank you again. Just gonna put you on hold make sure to get those questions submitted now. Thanks

All right. So few questions that we got in we can go through these now first one is is dry needling going to be covered now that there’s a CPT code for it. So the. CPT codes that get released are actually released by the AMA and that’s obviously different body than the then CMS. So I don’t know whether or not there will be reimbursement for it

I don’t know for sure on that one. I’d have to look it up but I would say that just because there’s CPT code being released for it does not mean there would be reimbursement for it those two things are disconnected. Next question is is there a demo version of what a non split PTA data and Report would look like so if in a non split scenario where you’ve got a PTA basically what they would be doing in the describe scenario is filling out the assistant minutes column with all of their minutes and it would populate with the modifiers for every charge and the modified justification would be service

Holy finished by PT. So it’d be real straight forward. Yeah, real simple and and the non split scenario. I apologize. I wanted to get screenshots and stuff in but it’s still too early for us to move to the development phase on this because we’re still waiting for that final rule. Basically, what we’re going to be doing is before the end of the year kind of tied in with that update will do another webinar you’ll have

Screenshots of everything so you’ll see exactly how this lays out. So we kind of had to talk a little bit more just in theory this time. We wanted to make sure to kind of catch the stuff early. So you guys were aware of what was coming down the pipeline. Okay. The next question is the way we schedule our ptas only do treatment with patients any evaluations that need to be done get scheduled PT will seek you modifiers automatically get entered on the charges when the PTA treats or will our to billing department at the mainly going to each claim for each day of service and plus EQ modifier

The billing department will not have to do that. After our update basically what will happen is those ptas? They’ll have to be filling out there minutes in the treatment section as assistant minutes and then the modifier will automatically get appended on so we do have changes in mind for all of this for you guys so that you guys aren’t having to do all of those after like I mentioned the one thing that you guys need to keep track of

Through this whole process is knowing in that split scenario how many minutes the pts are doing compared to the ptas that part we obviously can’t account for but as long as you document that information we’re going to be handling whether or not that modifier is going to be required and getting it into the system before the charges even get sent over to accounting

Next question is how will we submit the attestation for the Improvement activities? So the way we’re going to do that is just through administrator within TheraOffice as part of that queue for update. We’re going to have you go into there and enter in what are the Improvement activities are testing for real simple process, but we have that plan for the final update before the end of the year

Next question is how is reimbursement affected with the PTA treating the patient. So reimbursement will not be impacted in 2020 and 2021 but is currently being slated to have a 15% reduction in payment for services rendered in the 2022 year and forward after that. This is I was will say obviously they PTA is fighting this and lots of providers are fighting this a lot of people are not okay with this PTA cut and I think

You know, there’s a large contingent of people that believe that this is an unfair cut and it’s being fought for I will say though that this was kind of the price that was paid for that Financial cap repeal. So if this is taken away in some way I imagine cup can’t come elsewhere. So. Yeah, I don’t know exactly what’s going to happen

It’s a few years down the line before we get to the actual cuts for this and they’re having that kind of two-year implementation period where they’re trying to figure out what services pti’s are actually a rendering so we’ll see but yeah as of right now 15% reduction on any charges with the modifiers as of 2022

Okay

Next question all clinics are required to participate myth regardless of not meeting the previous criteria from participation. Nope. Criteria stays exact same as it was before in the previous year just know that it’s the determination periods for mips are kind of rolling year to year. So even though you weren’t required for 2019, you might be required for 2020

If you some of your provider saw an increased volume and Medicare patients in 2020, so it’s really really important that you check that participation lookup tool every single year and it’s kind of a pain especially if you have a lot of providers to be looking them up every year and seeing whether or not they’re required

If you don’t do that, you run a risk of one of your providers potentially getting hit with a. Nine percent penalty, which is really really big. So you’re going to have to that’s going to be part of your process every single year. You should kind of be monitoring it from within TheraOffice using your reporting to see kind of how many Medicare patients each your providers are treating whether or not you’re seeing spikes on that

I don’t know if you control it from the scheduling side, but it’s something you’re going to have to be aware of year to year because if you exceed those thresholds. It’s really really important that you participate in MEPS because that penalties going to its nine percent next year. It’s going to be eleven percent the year after that 13% of the year after that

It’s going to keep increasing. So make sure that’s number one. Most important. Take away with MEPS. Don’t get penalized.  Next question is claim based filing going away anytime soon. There’s nothing in the proposed rule about claims-based going away in 2020. I know that they don’t like it and they don’t want people to report on claims

So you always run a risk on that and you know, the other part of it is claims based reporting cannot report on all of the quality measures that are out there. So you might see a scenario with claims based reporting where you simply do not have enough measures to report on to successfully report in MEPS, so

Claims-based. It’s still an option for some people. It is a good option, but just be aware that that might not be the case. They’re not taking it away this next year though. Next question is if a PTA does all of the treatment what would they have to do? Basically just enter in the their minutes instead of entering into the minutes column

They don’t turn into his assistant then it’s column. We might look into like building out an alert on there. They’re flagged as a TTA in our system and they’re not filling out the assistant minute columns. So, you know, we’ll look into that but we’re going to keep it simple for everybody. We don’t have the final specs or any yet because again, it’s going to depend on that proposed rule

I think the de minimis standard is the point of contention that. Been hearing a lot about so if there was a change to kind of what we talked about today, I wouldn’t be surprised if it was to that 10% That’s a really really really low threshold. Again, if you’re treating a patient for 15 minutes, I guess depending on the method you use two minutes or three minutes might flag that so I would say that

Yeah, it’s it’s still kind of up in the air but for right now ptas it’s going to be kept real simple. All you have to do is just enter in what their minutes are that splits and are that’s a little bit tougher. All right last question that we have for now and feel free to get any other questions entered in if you guys have them the last question we have is our rehab agencies required to participate mips

This is still the same as the previous year in that if you submit institutional claims to Medicare. You are not required to participate in mips. They don’t know how to fix that problem. That was the last thing that I heard on that subject. It was it was a little bit of time ago is about a year or two ago, but when the discussion of institutional based submissions

Like rehab agencies, they don’t know how to get the requirements out of there because when you’re submitting your institutional claims to Medicare, you’re not submitting them with a provider and because of that they don’t know who’s required and who’s not required because all of the thresholds for whether or not you’re required are based off of individual providers and the number of visits tied to them

So they don’t even know how to reconcile that I haven’t heard of any. Possible solutions for that. I’ve heard that mention about talking about that but. No everything I’ve heard so far as Raven she rehab agencies no changes there. You guys are still exempt from MEPS. So congratulations, although we are seeing some really positive results so far on 2019 with regards to the customers that are participating in the registry

So we’re hoping optimistically that we’re going to see some nice. Positive payment adjustments for those customers that are submitting on maps. So while there was a little bit of extra work, you know, you can kind of get it set into motion and then hopefully get some some increases in payment which is kind of rare words for the PT industry today

So hopefully some good news. They’re coming up once we get that data submitted in quarter one of 20. 20 so alright that looks like it is it for questions quick webinar today. So you guys get an extra few minutes here. Thank you again for everyone attending today. We’ll do a follow-up with the copy of the PowerPoint and let you guys know when this webinar get toasted

Feel free to let us know any other follow-ups that you guys have any other questions and stay tuned as we have more information available when that final rule gets released. Thanks, and have a great day. Bye.

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