The House Continuing Resolution (CR) to keep the federal government operating after February 8 contains proposals to change the way home health payments are structured under Medicare. The bill eliminates use of the therapy thresholds in the home health payment method, effective in 2020.
“This is a large bill affecting Medicare and many, many other programs,” noted Heather Parsons, Associate Chief Officer, Federal Affairs, at AOTA. “There is a very long list of ‘offsets,’ or ways to pay for increases for rural health, hospitals, ambulance services, and other programs like federal health centers.” Parsons notes that among the other offsets are changes to occupational therapy assistant payment that will also have impact on occupational therapy. (See article titled, "Understanding the Proposal to Change OTA Payments.")
Elimination of the therapy thresholds has been a feature of the larger Home Health Grouping Model (HHGM) which was proposed last year but not implemented. Therapy thresholds as currently implemented increase home health payments as more therapy is provided. The current thresholds provide for increased payments after 6 therapy visits and gradually increase to a top amount of 20 therapy visits.
AOTA has opposed removal of these therapy thresholds without the assurance that requirements will be put in place to assure that beneficiaries get the skilled therapy services they need rather than substitutions such as aide services. AOTA reported previously on the original CMS proposal and the successful grassroots campaign to have the proposal withdrawn.
Amy Lamb, OTD, OT/L, FAOTA, AOTA President, said that “While AOTA supports appropriate changes to home health payment, this raises the possibility of patients being denied medically necessary therapy.” She notes that AOTA and our members have been critical of the HHGM since it was proposed, arguing that there must be quality and reporting requirements to assure that skilled services are provided when needed. “We cannot allow therapy to be eliminated from home health by this policy,” she emphasized.
The bill also requires CMS to hold a Technical Expert Panel (TEP) on the HHGM between January 1, 2018, and December 31, 2018. Last week a TEP was held but there was no indication that these home health changes would be included in the CR. Karen Vance, OTR/L, represented AOTA at the meeting last week and reported that the discussions at that time were very productive. The CR, however, gives great flexibility in designing the PPS to CMS with the TEP comments only being recommendations on priorities for the PPS.
AOTA’s position has always been to support provision of skilled therapy to prevent abuses such as substituting other providers or ignoring therapy needs. Further, AOTA supports adequate quality reporting on functional outcomes to protect beneficiary access to appropriate, beneficial services to which they are entitled under law.
“Therapy may have been over utilized by some providers, but the elimination of the therapy thresholds circumvents existing processes and research. There are no proper beneficiary protections for access,” said Christina Metzler, AOTA Chief Public Affairs Officer. “The bill only says the therapy cap thresholds are eliminated. Focus must be on putting protections in place prior to implementation. Our work on Medicare home health is not done.”
More information on other policies in the Continuing Resolution:
Permanent repeal of the Medicare Therapy Cap
Changes to Medicare reimbursement for occupational therapy assistants