The APTA 2013 position statement on payment reform can be found on its website.
The APTA has chosen to propose coding system changes (Alternate Payment System-APS) through the AMA CPT Editorial Panel/RUC process.
The APTA’s effort at driving payment reform is a fear based decision and strategy 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.
Over the last year or two, we have expressed significant concerns about this proposal (see Resources) including:
o Lack of value/quality components
o Lack of any published reliability and validity in the piloting
o Lack of member involvement
o Lack of transparency
o Despite the significant changes in codes/code definition to capture clinical judgment, severity and intensity, there is no clear connection to value or quality.
o Associated payment methodologies for the APS proposal have received little or no attention. Reimbursement is a critical issue for any practice and must be part of the discussion now, not after adoption. The AMA RUC process does not prohibit interaction with APTQI beyond surveying.
As a result of APTQI and other trade group insistence, the APTA/AMA CPT workgroup agreed to conduct a pilot and then failed to be transparent in sharing those results with its own members! The latest information on the website dates back to 2013.
The proposed system of new CPT codes will still be “Fee For Service” with all of the existing burden that exists today and lacking any clear plan to address regulatory concerns (MPPR, etc.).
It has been argued by APTA that the current CPT therapy coding system was never tested for statistical reliability and validity and that is not important and slowing down the process.
Despite numerous attempts to collaborate with the APTA, including offering resources (financial and otherwise) in an effort to be both solution and action oriented, the APTA’s action has been to continue pushing forward the plan at the AMA CPT Editorial Panel/RUC level.
In various communications over two years, both informal and formal, our concerns have been communicated to the APTA by the APTQI including a presentation by APTQI members to the APTA Board in April 2015.
The APTA has acknowledged our concerns yet continues to move forward with the current flawed payment model at AMA. Their primary message is centered around on convincing us as to why the APS proposal “is the only way” to accomplish physical therapy coding and payment reform.
We do not support the current alternative fee for service payment system and we think others would agree if given all the facts. We encourage you to inquire about the proposed APS model working its way through the AMA committee process and gather your own conclusions. We also encourage you to acquire a copy of the “confidential” pilot study results.
You may reach out to any of our Board member company representatives if you wish to have further discussions involving the most significant issue facing our industry in the past forty plus years. Millions of dollars have been spent on this issue by CMS and others. Other proposals, as mentioned prior, do exist. We by no means think that we (or anyone) have the perfect ultimate answer today. That said, we do believe that there are many great minds in our profession across the country and with true open discussion and collaboration we can create a promising future that supports the triple aim of healthcare.