Therapy Cap

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WELCOME!
2012
KPTA Town Meeting
Kansas Physical Therapy Association
Topeka, Kansas 66603
785-233-5400 Fax: 785-290-0476
Email: kpta@kpta.com
www.kpta.com
1
KPTA MISSION
The Kansas Physical Therapy Association is the
member organization of physical therapists and
physical therapist assistants that represents,
promotes, and advocates for the profession of
physical therapy, promotes evidence-based practice,
and assists members in addressing the health and
wellness needs of individuals in Kansas.
KPTA VISION
Consumers have unrestricted access to physical
therapists as the practitioner of choice for diagnosis,
evidence-based interventions, prevention of functional
limitations and disabilities related to body function
and structure, and promotion of physical activity and
life participation. Physical therapists and physical
therapist assistants, under the direction of physical
therapists, are recognized and valued as the only
providers of physical therapy.
2012 TOWN MEETING
SCHEDULE
 K.C. at Shawnee Mission Medical Center – 11/19 6:30
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8:30
Topeka at Rebound Physical Therapy – 11/6
K.C. at Olathe Medical Center – 11/8
Colby at Colby Community College – 11/15 (7-9pm)
Great Bend at Advance Therapy & Sports Med. – 11/8
(6:15-8:15 pm)
Manhattan at Mercy Regional Health Center – 11/13
(6:30-8:30 pm)
Salina at Southwind PT – 11/14 (6:30-8:30 pm)
Wichita at Via Christi - St. Francis Campus – 11/8
Pittsburg at Via Christi Hospital – 11/5
4
SAVE THE DATE!
KPTA Spring Conference in
Wichita
April 5-7th, 2013
5
AGENDA
 Welcome/Introduction
 Professional Competency Update
 Payment/Reimbursement Issues
Update
 2013 KPTA Legislative Plan
Update
 House of Delegates Update
6
GREAT NEWS TO
START OFF OUR
EVENING!
7
KPTA Membership Numbers
 PTs - 613
 PTAs - 119
 Students - 353
 Overall - 1085

Never cracked 1000 until this year!
8
Professional Competency Updates
 NOW IS THE TIME to subscribe to the 2013-2014
CE Tracking Service
 Are you wishing it was easier to keep track of all your
continuing education hours? Let the Kansas Physical
Therapy Association help you!
 Subscribe to the KPTA Tracking Service by February
28, 2013 at the early bird rate of only $50 for PTs and
$40 for PTAs for the entire two-year 2013-2014 CE
cycle –
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That breaks down to be less than $0.10 per day!
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Professional Competency
 By subscribing to the KPTA Tracking
service, you will receive and benefit
from:
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An electronic record of all your CEs, and online
access to your credit report at any time, via the
KPTA website: www.kpta.com.
Elimination of the likelihood of being audited by
the Kansas State Board of Healing Arts, upon
successful completion of your CE hours.
A committee of peer professionals reviewing the
quality of your CEs to protect your profession.
10
Tracking Service continued…
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Peace of mind knowing that completed CE
courses will be reviewed to ensure they meet
current CE criteria and will be accepted as CE by
the State Board prior to licensure renewal.
Ability to check on pre-approved courses via topic
or location.
Peace of mind knowing that all records are kept
safely, securely and indefinitely, and may be
accessed at a future date if you need for
advanced certification, future employers, or if
you’re simply continuing with your education.
11
Update on the revision of the Rules and Regs
regarding Continuing Education Requirements
What takes almost as long as
to change as our Practice Act
to include Patient Self
Referral?
12
ANSWER
 Changing any of the Rules & Regulations of
the Practice Act
 Revision is in the process. It has been
approved by the Attorney General’s Office
and waiting to be given a public hearing.
13
REVISION OBJECTIVES
 Revision to include:
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Credit for being a CI to PT/PTA students
Credit for Successful completion of FSBPT
Practice Review Tools
Credit for Successful completion of the KS
jurisprudence exam
Adding Professional Leadership Activities
14
Professional Competency
 Don’t delay, sign up today!

Fees increase to $60 for PTs and $50 for
PTAs on March 1
 Register today to take advantage of both the savings
and the benefits of Tracking with the Kansas Physical
Therapy Association.
 An application is available tonight or download the
KPTA 2013-2014 Tracking Subscription
form: http://www.kpta.com/resources/1314_Tracking
_Subscription_Form.pdf
15
REIMBURSEMENT
NEWS
16
Therapy Cap: Exceptions
 January 1 - October 1, 2012: an automatic
exception to the therapy cap may be made when
documentation supports the medical necessity of the
services beyond the cap. Providers should use the
KX modifier.
 October 1, 2012 - December 31, 2012: an automatic
exception may be made for claims between $1880$3700 (use KX modifier).
 October 1, 2012 - December 31, 2012: Claims
exceeding $3700 in expenditure will be subject to
manual medical review to be paid.
17
2012 Therapy Cap: Hospitals
 Starting October 1, 2012 the therapy cap
with an exceptions process will apply to Part
B SNF, CORF, ORF, private practices,
Rehabilitation agencies, and Hospital
Outpatient Departments (critical access
hospitals are exempt).
 Hospitals would no longer be subject to the
therapy cap after December 31, 2012 unless
Congress extends the provision in future
legislation.
18
2012 Therapy Cap:
Dollars Accrued
 Therapy cap is based on the allowed
charges.
 Medicare Part B will pay 80% of the allowed
charges ($1504.00) and the beneficiary will
be responsible for the remaining 20%
($376.00).
 MPPR reduction is included in the amount of
the allowed charges.
19
2012 Therapy Cap:
Dollars Accrued
 C-SNAP uses the Centers for Medicare &
Medicaid Services (CMS) beneficiary
eligibility system to provide our Real-time
Eligibility data.
 http://www.wpsmedicare.com/j5macpartb/res
ources/claims_elig_tools/csnap/
20
Therapy Evaluations
 Therapy evaluations after the therapy caps
are reached to determine if the patient needs
therapy services would be exempt from the
cap. (97001 (PT evaluation) & 97002 (PT
re-evaluation).
21
Therapy Cap:
Manual Medical Review
 Phase I providers: Subject to manual medical review from
October 1‐December 31, 2012.
 Phase II providers: Subject to manual medical review from
November 1‐December 31, 2012.
 Phase III providers: Subject to manual medical review from
December 1‐December 31, 2012.
 List of NPIs and phases to which they are assigned is
available at:
 https://data.cms.gov/dataset/Therapy-Provider-PhaseInformation/ucun-6i4t
22
Therapy Cap:
Manual Medical Review
 PROVIDERS SHOULD NOT SEND
IN CLAIMS FOR PRE-APPROVAL
BEFORE THE SCHEDULED
BEGIN DATE FOR EACH PHASE
(see next slide for dates)
23
24
Therapy Cap:
Manual Medical Review
 PROVIDERS MUST SUBMIT REQUEST ON
CORRECT FORM
(wrong form = no review)
 PROVIDERS SHOULD CONTACT THEIR
REPSECTIVE MAC OR LEGACY TO
DETERMINE THE APPROPRIATE FORM
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Therapy Cap:
Manual Medical Review
 FORM MUST BE MAILED
 DO NOT FAX FORM
 RECOMMEND CERTIFIED MAIL
 WPS WILL NOT TRACK IF IT WAS
RECIEVIED or NOT RECIEVED
30
Therapy Cap:
Manual Medical Review
 Medicare Administrative Contractors (MAC) will have 10
business days to make decisions regarding whether
services will be approved over the $3700 amount. If a provider
request is not reviewed by MAC within 10 business days,
claims beyond the $3700 threshold will be approved.
 Advanced approval will allow an additional 20 treatment days
beyond the $3700 amount.
 Provider will use modifier on claim form to indicate advance
approval given.
 Advanced approval does not guarantee payment.
 Retrospective review may still be performed.
 There is an APPEAL PROCESS for “Retrospective Review”
 NO APPEAL PROCESS for Manual Review
31
Therapy Cap:
Manual Medical Review
 If a provider does not request advanced
approval prior to providing services over
$3700, payment for the claims will stop
and a request for medical records will be
sent to the provider.
 The provider will be subject to prepayment
review for those claims and the time frame for
review will be approximately 60 days
32
Part A (facilities) Mail To:
WPS Medicare Attention: MR Department
3333 Farnam St., Suite 600
Omaha, NE 68131
J5 / J8 Part B (practitioners) Mail To:
WPS Medicare Attention: MR Department
1717 West Broadway
Madison, WI 53713
Legacy Part B (practitioners) Mail To:
WPS Medicare Attention: MR Department
8120 Penn Ave S, Suite 200
Bloomington, MN 55431
33
Therapy Cap:
Manual Medical Review
 There is NO APPEAL PROCESS with the
Manual Review (must submit another review)
34
Therapy Cap: Example
 Patient A receives therapy services at a SNF (Part B)
from January 15, 2012-April 20, 2012 and accrues
$3800.00 toward the therapy cap.
 Patient A is discharged from the SNF and later goes
to an outpatient hospital department for therapy on
October 15, 2012.
 The hospital would need to request manual medical
review to get coverage for these services because
the patient has already exceeded the $3700
threshold.
35
Therapy Cap: Example
 Patient A receives therapy services from an outpatient
hospital from February 15-May 15, 2012 and accrues
$3800 in therapy services.
 Patient A goes to a private practice for services on
September 20 until November 15. Private practice
submits the claim on September 20 for payment and the
common working file reflects $0 toward the cap.
 On October 1, the $3800 from the hospital therapy would
be added to the common working file; for dates of service
provided to patient A after October 1 the provider would
need to seek advanced approval (if a phase I provider).
36
Therapy Cap Example
 Patient A received $4000 of services from a hospital
stay from January 15—May 15, 2012.
 From July 22, 2012 –August 25, 2012 patient A
received services from a private practice.
 The private practice would not need to submit the KX
modifier or submit a request for advanced approval
as Patient A was discharged prior to October 1, 2012.
37
Therapy Cap Example
 “A beneficiary was in a skilled nursing facility (SNF) and
exhausted their SNF benefit days under Part A.
 The beneficiary continued to receive therapy services under
Part B totaling $3,600 (all dates of service before 10/1/2012).
 The beneficiary was then discharged from the SNF and received
therapy services from an independently practicing PT totaling
$1,800.
 The independent PT billed in November 2012 for services
provided after 10/1/2012.
38
Therapy Cap Example
 The MAC received the claims and processed them. After these
claims were processed the MAC received the SNF Part B claims
totaling $3,600 and processed them.
 Had these claims been received in advance of the independent
PT services the independent PT would have been required to
have the services approved in advance.
 In circumstances such as the example above the contractor is
not required to perform post payment review on the $1,800
provided by the independent therapist. “
39
Notification to Beneficiaries
 Beneficiaries who have received $1700 or more of
therapy services in 2012 received letters in
September 2012 providing them information about
their potential financial liability for services over the
therapy cap amount.
 APTA provided a document for beneficiaries to
provide info on cap.
 http://www.moveforwardpt.com/Resources/Advocacy.
aspx
40
Therapy Cap:
Collecting Out of Pocket
 If a patient does not qualify for an exception,
the provider can collect out of pocket
payment from the beneficiary.
 It is advisable to give the beneficiary an
Advanced Beneficiary Notice (ABN) if
Collecting Out of Pocket. Revised ABN form
(Form-R-131) available on the CMS website
at: https://www.cms.gov/BNI/02_ABN.asp
41
Therapy Cap:
Collecting Out of Pocket
 Provider can determine the amount of
payment to collect from the patient; it does
not have to be the fee schedule amount.
 Providers should avoid deep discounts or
providing services for free as that could
violate anti-kickback statutes.
42
Therapy Cap:
Collecting Out of Pocket
 If provider would like a denial from Medicare in order
to bill a secondary insurer after the therapy cap
amount is exceeded, the provider could submit claim
with a modifier:
 GX Modifier:
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Notice of Liability Issued, Voluntary Under Payer Policy.
Report this modifier only to indicate that a voluntary ABN was
issued for services that are not covered.
Medicare will automatically reject claims that have the –GX
modifier applied to any covered charges.
 GY modifier:
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Notice of Liability Not Issued, Not Required Under Payer
Policy. This modifier is used to obtain a denial on a non
covered service. Use this modifier to notify Medicare that you
know this service is excluded.
43
APTA RESOURCES
 APTA has developed a Medicare Therapy Cap
Resources website. This website compiles relevant
information available from APTA and CMS in one
place.
 You can view the website by clicking here or by going
to APTA’s homepage and clicking Learn More on the
Medicare marquee. Please share this information
with your colleagues and staff
 Questions regarding the therapy cap may also be
emailed directly to CMS at
therapycapreview@cms.hhs.gov.
44
2013 Proposed Physician Fee
Schedule Rule
 On July 6, 2012 the Centers for Medicare and
Medicaid Services (CMS) released the proposed
2013 Medicare physician fee schedule rule that
updates 2013 payment amounts and revises other
payment policies.

http://www.cms.gov/Medicare/Medicare-Fee-forService-Payment/PhysicianFeeSched/PFS-FederalRegulation-Notices-Items/CMS-1590-P.html
 CMS will publish a final rule by November 1, 2012
which will become effective for services furnished
during calendar year 2013.
45
MEDICAID
 KanCare benefit packages outlined (By Dave
Ranney; Wednesday, September 26, 2012)
 Comparison of benefit packages offered by
KanCare MCOs
46
47
AFFORDABLE CARE ACT
 A brief outline of the AFFORDABLE CARE
ACT (ObamaCare) can be accessed at:
 http://en.wikipedia.org/wiki/Patient_Protection
_and_Affordable_Care_Act
48
TRICARE
 TRICARE WILL NOT reimburse for services
furnished by physical therapist assistants that are
provided in a:
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Physical therapy private practice
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Freestanding clinic
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Home care agency

Comprehensive outpatient rehabilitation facility
(CORF)
49
TRICARE
 TRICARE WILL reimburse for
services furnished by a physical
therapist assistant in a:
 Hospital
 Skilled
nursing facility
50
KANSAS WORKER’S
COMPENSATION
 Kansas Department of Labor: Division of
Workers' Compensation
 Kansas WC contacts:
http://www.dol.ks.gov/WorkComp/Default.asp
x
51
2012 KPTA
LEGISLATIVE PLAN
MOVE FORWARD!
52
KPTA LEGISLATIVE DAY
In Topeka on JANUARY 30,
2013
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“Squeaky wheel gets the
grease…”
 We will continue to
push Patient Self
Referral (the Artist
Formerly Known as
Direct Access)
54
KPTA House of Delegates Report
APTA House of Delegates
June
2012
55
RC 2-12 PHYSICAL THERAPIST RESPONSIBILITY AND
ACCOUNTABILITY FOR THE DELIVERY OF CARE
 Position statement that physical therapy is
provided by or under the direction of the
physical therapist. Evaluation remains the
complete responsibility of the physical
therapist.
 Proviso that the position becomes effective
when all necessary changes are in place,
including approval of new policies by the
House.
 Annual reports beginning in 2013
PASSED as Amended
56
RC 2-12 PHYSICAL THERAPIST RESPONSIBILITY AND
ACCOUNTABILITY FOR THE DELIVERY OF CARE (Continued)
 Charge to explore practice models
responsive to society’s needs by
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Identifying changes needed
Amending any APTA documents as
necessary
Approval of the model by the House
 Interim report in 2013, final report in 2014
PASSED as Amended
57
RC 13-12
AMEND DIAGNOSIS BY PHYSICAL THERAPISTS
 Physical therapists may order imaging and
other studies
 Physical therapists may perform or interpret
selected imaging and other studies
PASSED as Amended
58
RC 14-12 PHYSICAL THERAPIST’S ROLE IN MANAGEMENT OF
THE PERSON WITH CONCUSSION
 Physical therapists participate with a
multidisciplinary team in education,
prevention and management of
concussion
 Individuals with concussion
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should not return to organized activity
without written clearance of a health care
professional trained in concussion
management
should not return to selected activities until
a health care professional trained in
concussion management has determined
they should return to the activity
PASSED as Amended
59
RC 18-12 AMEND: EDUCATIONAL DEGREE QUALIFICATION
FOR PHYSICAL THERAPISTS
 Amend policy to show that, effective 2018,
the Doctor of Physical Therapy Degree is the
minimal educational qualification for
graduation
 PASSED (Consent)
60
RC 20-12 EXPLORE FEASIBILITY OF TRANSITIONING TO AN
ENTRY-LEVEL BACCALAUREATE PTA DEGREE
 Conduct a feasibility study including
 Content of a potential 4 yr. curriculum
 Models for baccalaureate education
 Mechanisms for 2 yr institutions to grant
baccalaureate degree
 Models for PTAs with AA degrees to earn
the baccalaureate degree
 Any necessary practice act changes
 Interim report in 2013, final report in 2014
 PASSED as Amended
61
RC 22-12 RESOURCE MATERIALS FOR PHYSICAL THERAPISTS
AS EXPERT OR FACTUAL WITNESSES
 Make available resources for use by physical
therapists (PT), physical therapist assistants
(PTA), and PT and PTA students to serve as
expert or factual witnesses.
 PASSED as Amended
62
RC 23-12 STANDARDS OF CONDUCT IN THE USE OF SOCIAL
MEDIA
 Adoption of a position that, in using social
media, PTs and PTAs should
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Consider whether and how to interact with
patients through social media
Be clear when speaking as an individual as
opposed to a representative of an
organization
Identify and correct mistakes
Apply the Code of Ethics for PTs and
Standards of Ethical Conduct for PTAs to
their engagement in social media
PASSED as Amended
63
RC 26-12 RESOURCE MATERIALS FOR PHYSICAL THERAPISTS
PRACTICING IN THE EMERGENCY DEPARTMENT
 That APTA develop additional resources
supporting the role of the physical therapist in
the Emergency Department
 PASSED
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RC 27-12 PHYSICAL THERAPISTS AS EXPERT PROVIDERS OF
EXERCISE AND PHYSICAL ACTIVITY PRESCRIPTION
 Position that
 APTA promotes as providers of choice for
exercise and physical activity prescription for
persons with noncommunicable diseases
(NCD) (eg, heart disease, stroke, chronic
respiratory diseases, diabetes, certain
cancers)
 APTA seeks participation in development of
exercise and activity guidelines for these
NCDs
 PASSED (Content)
65
Thank you
for attending the KPTA Town Meeting.
If you have any questions regarding
membership or any of the issues discussed
tonight please contact the KPTA office at
785.233.5400 or kpta@kpta.com.
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