Introduction

First, a quick introduction. We (the APTQI) are among the nation’s leading providers of outpatient rehabilitation care, and collectively employ or represent several thousand physical and occupational therapists, and furnish physical therapy services on an annual basis to hundreds of thousands of Medicare beneficiaries.

What do we support?

We support reform initiatives in alignment with the Triple Aim of Healthcare and a transparent health care environment.

We support Physical and Occupational Therapy as a lower cost alternative to other options (imaging, surgery, medications) which is consistent with the ACA healthcare reform law that encourages less costly interventions and results in improved patient reported outcomes.

We believe our position is also consistent with the Physical Therapy Business Alliance (PTBA) position which can be found here.

We support moving away from regulatory administrative burdens that impact our clinicians and moving towards incorporating value, quality, clinical complexity and clinical judgment.

We support the premise that PT/OT services are a key component in the continuum of care.

We believe that to obtain the best seat at the table in negotiating for these services in any current or future episodic care or ACO environment, we must demonstrate quality care delivery, successful patient reported outcomes and exceptional patient experiences.

We believe that any transformational payment reform should be successfully piloted for reliability and validity as well as financially modeled.

We have been told on multiple occasions by the APTA “the APS coding and payment reform train has left the station and you better get on Board.”   We support transparency and collaboration in the process beyond lectures at conferences and this level of communication to its members. Transparency means more than patronizing lectures.

We believe the APTA’s effort at driving payment reform is a fear based and strategy decision (if we don’t do it someone else will and that will be bad) that wrongly assumes consolidating misvalued codes into an alternative fee for service system will somehow make coding valuation a non-issue for CMS and commercial payors.

We believe there may be some issues with the current therapy coding system, but we are not aware of any study that substantiates the degree of variability noted with the Proposed APS CPT Codes. In any case, transforming the “current fee for service” CPT therapy coding system with an “unreliable and subjective fee for service system” that does not consider quality and outcomes is strategically flawed.

We believe that all of the above are important to consider across all practice settings (private practice, acute care, skilled nursing, etc.) as any risk, benefit or change will result in an impactto all.

Last, but most certainly not least, we FULLY support our employees’ professional development in numerous areas as evidenced by our support of continuing education, Board Certifications, etc.

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