Medicare Proposed Rule: Functional Data Collection for Outpatient Therapy (beg. January 2013)
Last month the Centers for Medicare & Medicaid Services (CMS) issued the 2013 Medicare Physician Fee Schedule Proposed Rule. This proposed rule will impact payment for outpatient therapy across settings beginning next calendar year. Notably, the proposal includes a plan to collect data on patient function beginning January 1, 2013. The data would be collected using new G-codes (a GXX1-XX7 series and a GXX8-XX25 series) along with modifiers (XA-XL) reported on the claim form. CMS plans to use the information collected to measure patient functional improvement and ultimately fundamentally reform the payment system for outpatient therapy.
Below are links to the proposed rule as well as an AOTA analysis (the proposal begins on Federal Register page 44765 – i.e., page 45 of the pdf). Comments are due to CMS by September 4, 2012, and AOTA’s comments to the agency will have an impact on the way the functional data is collected and how it is used. We need your help! Please review the materials and respond to any/all of the questions. AOTA staff will rely on your input when drafting the association’s comment letter.
QUESTIONS:
- Do you currently use an outcomes assessment tool (eg, the AM-PAC)? Would your tool map appropriately to CMS’s proposed scheme to measure improvement?
- How burdensome would it be for providers to be trained to comply with this proposal and to collect the required information in the course of practice?
- Would a simpler system of six function-related G-codes be preferable, such as the one below [STATS Option 1]?
GXXXU – Impairments to body function and/or structures (current)
GXXXV – Impairments to body functions and/or structures (goal)
GXXXW – Activity limitations and/or participation restrictions (current)
GXXXX – Activity limitations and/or participation restrictions (goal)
GXXXY – Environmental barriers (current)
GXXXZ – Environmental barriers (goal)
- Would the 12 modifiers denoting improvement sensitive work for your practice? Sensitive enough/too sensitive?
- CMS proposes to require G-code/modifier reporting at episode outset (evaluation or initial visit), and once every 10th treatment day or at least every 30 calendar days, whichever time period is less. This coincides with the progress note reporting requirements found in the Medicare Manuals. Should CMS modify these 10/30 reporting requirements to one based on the number of treatment days (such as 6 or 10)? What would be the clinical impact of such a change?
Send your thoughts to rrpd@aota.org or jhitchon@aota.org.
CY 2013 Medicare Physician Fee Schedule Proposed Rule [see pp. 45-53 of the pdf]
AOTA Analysis of the Proposed Rule
