Medicare Compliance & Reimbursement

Yearning for the day when the Medicare outpatient therapy caps no longer plague your home health agency's Part B business? In 18 months, you'll be back at square one with the exceptions process expiring once again.

The good news: The Centers for Medicare & Medicaid Services is hoping to break that pattern by developing alternatives for Part B therapy payments. CMS' Developing Outpatient Therapy Payment Alternatives (DOTPA) project is in the birthing stages of its five-year lifespan -- and now's the time to voice important concerns to CMS.

Just as CMS is aiming to better link patient assessment, outcomes and payment methodology in the Post-Acute Care Payment Reform Demonstration (PAC-PRD), the agency has contracted RTI International to do a similar task with DOTPA for Part B therapy services. The project will involve data collection from a range of outpatient settings with the goal of developing case mix adjusters and outcomes measures that support alternative payment models for CMS to consider at the end of the project. And ultimately, project leaders want more emphasis on patient need and less on setting.

But don't expect CMS to start from scratch. "Our focus is on alternatives for case mix and outcomes that generally fit within the existing system -- the Medicare Physician Fee Schedule," said Edward Drozd, RTI's DOTPA project director, during an Aug. 6 CMS Open Door Forum on the initiative.

What this means: Like with OASIS and home health PPS, some aspect of payment would be adjusted based on underlying patient characteristics such as diagnoses, function, cognitive status, pain, etc. that would be collected in an assessment instrument, Drozd explained. "Right now, we're trying to collect information to see if those or others would be potentially useful case mix adjustors to payment."

Year one of the DOTPA project is dedicated to developing an appropriate data collection tool(s) -- so now's the time to offer your two cents. And based on what the rehab community knows about the project thus far, a lot of concerns have surfaced.

Example: Multiple participants in the Open Door Forum expressed concern over RTI's plan to have two separate data collection instruments: one for the non-ambulatory population in outpatient settings and one for the ambulatory population.

"By defining your study between ambulatory and non-ambulatory, you have inherently separated it by setting," commented a representative from RehabCare. "The group should acknowledge that setting will play a role, and it will impact the methodology you come up with."

Providers also worry about the provider burden of using a data collection tool. "How are you going to make sure this is a process the clinician can not only do, but do effectively, especially if it's a paper-based system?" asked Ken Harwood of the American Physical Therapy Association.

If you want to make sure your patient population and your home health agency setting is appropriately represented in the study, you can volunteer. RTI is looking for roughly 200 providers nationwide, including hospital outpatient departments, nursing facilities, private practices, home health Part B, and other settings where patients are receiving outpatient therapy services.

"We'll enroll these providers over a one-year period, starting in the second year of our project," Drozd said. Then, the chosen providers would participate for up to six months.

Meanwhile, some good things may happen before the project is even finished. "CMS hopes that the preliminary data collected in this project might support short-term steps taken to address the issues surrounding the therapy caps," said Renee Mentnech, with CMS' office of research development and information.

Note: You can send your comments about the project to optherapy-comments@rti.org. For more information on the project and participating, go to http://optherapy.rti.org.