Alternatives to the Therapy Caps? [07-22-10]

Filed under: Industry Updates — Editor @ 8:35 am

In another section of the physician fee schedule rule published in the Federal  Register  (“Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2011”), CMS noted that unless Congress acts, the therapy caps exceptions process will expire on December 31, 2010. CMS proffered for discussion and comment three possible alternatives to the outpatient therapy caps.  With the assistance of contractors, CMS examined therapy services with an eye toward determining a patient’s condition so that “an objective payment policy could be developed that would ensure appropriate payment for appropriately utilized services.”  CMS stressed that it was interested in discussing “several potential alternatives” and is “not proposing either short-term or long-term payment alternatives to the therapy caps at this time.”  CMS also asserted that the claim that implementing any one of the three alternatives would not require legislation granting it additional authority.  The first option would modify the current exceptions process “to capture additional clinical information regarding therapy patient severity and complexity in order to facilitate medical review.”  The second option would “involve introducing additional claims edits regarding medical necessity, in order to reduce overutilization.”  And the third option discussed would “adopt a per-session bundled payment” that would vary according to the patient’s condition and the level of services provided during the session.

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