Alliance Update – July 16, 2015

APTQI Alliance Update

Well these past few weeks have seen the most public discussion to date with respect to the APTA’s proposed coding changes for the 97000 series codes that govern the billing of our services. Our Alliance’s announcement that we would not continue to financially support our trade group while they were actively working on a plan that we believed (and still believe) will be detrimental and damaging to our member companies, as well as to the entire industry, has brought about a rising tide of awareness and discussion on this critically important topic.

Now is the time when the APTA must step forward and release the FULL and unabridged version of the Gage study which was done to measure the reliability and validity of this proposed coding change. As we mentioned in our earlier correspondence, we received a copy of this report (with all of the data) some 7 months ago under a signed letter of confidentiality. Isn’t it time that the APTA and its leadership trust the members they have been commissioned to serve and transparently step forward with a full copy of that report? Additionally the APTA and its CEO, Michael Bowers have cited “confidentiality provisions” around the AMA process. Our Alliance is interested to know if Mr. Bowers or anyone at the APTA has requested that the AMA relieve them from any confidentiality provision and allow all of the proposed code set information to be released immediately. Additionally, why is there still no full release of the Barbara Gage study 7 months after we received a copy?

It is time to get everyone on the same page with respect to this coding proposal allowing all members to have full access to all of the available information. While we might not all fully agree, then and only then will everyone have the information necessary to make an INFORMED decision with respect to what it might mean for them and their business. It is well beyond time for the APTA to be FULLY transparent about ALL ASPECTS of the proposal and the study results which our member companies, through individual memberships and other events, have helped to fund. It is time to work on a payment reform solution that isn’t just a highly subjective, fee-for-service bundle which will not advance the triple aim goals of healthcare reform, but will create tremendous havoc in the process. It is beyond time to openly and fully discuss all of these issues in the light of day for the entire profession rather than rely on the crumbs, bits and pieces approach we have gotten so far. I think our Alliance and all of its large and small company members as well as our profession deserves better.

To those who have worked to try to build a bridge (even though we haven’t yet fully succeeded), Justin Moore in particular, I am hopeful that he (and we) can convince whoever holds the ultimate decision making power at the APTA that it is time to truly listen to its constituents. When our Alliance met months ago with the APTA board to formally share our concerns with them, we sent a letter (read letter) in advance of that meeting outlining our many concerns. Unfortunately, we were told at the meeting that while they agreed with all of the points in our letter that too much time had been invested in THIS proposal to turn back. Is that what we should really want and expect from our trade group? Shouldn’t we want the RIGHT solution?   We believe thoughtful, well-structured payment reform is necessary. We do not however support what is being proposed by the APTA. It is our sincere hope that at some point we can work together to develop an alternative proposal that puts physical therapy in a position for long-term success as a result of our long-standing contributions. Our profession is certainly part of the solution in reducing unnecessary and wasteful healthcare and we should fight for the RIGHT solution and not accept one that will hurt our practices and our patients. Thank you for standing with us as we work on this important and challenging opportunity. As always, we will do our best to keep you apprised as this issue continues to unfold.


APTQI members and Associates


Actions taken by the APTA

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.


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.