5 min rule

CMS Final Rule: Countdown to 2024 Begins

If you've got your finger on the pulse of the ever-evolving healthcare scene, you've probably heard the buzz about the CMS Final Rule, a roadmap to reshape how we receive and deliver healthcare in the U.S. by 2024. Exciting, right? Well, get ready because the countdown to this has officially begun! It's not just any rulebook; it's a comprehensive game-changer set to shake up the way we get and give care. Think of it as a script for a blockbuster movie, with interoperability, patient access, and value-based care initiatives playing the leading roles. This rule isn't your typical bureaucratic jargon; it's a script that's set to influence how healthcare providers, payers, and even patients interact. Want a sneak peek? Here it is.

The Conversion Factor Takes Another Hit

One perennial concern for healthcare providers is reimbursement rates, and unfortunately, 2024 brings another cut to the conversion factor. The conversion factor for the 2024 PFS calendar year drops to $32.74, representing a 3.4% decrease from the previous year. As rehab therapists grapple with evolving healthcare landscapes, understanding the financial implications of these changes is crucial.

Therapy Threshold Adjustments

Rehab therapists closely monitor the therapy threshold, a pivotal factor influencing outpatient services. In CY 2024, the KX modifier threshold for combined physical therapy and speech-language pathology services is $2,330, while occupational therapy services share the same threshold. Looking ahead, the targeted medical review (MR) threshold is established at $3,000 through CY 2027, with annual updates based on the Medicare Economic Index (MEI) starting from CY 2028.

Evolution in Supervision Rules

Supervision rules have been subject to increased scrutiny, particularly with the advent of remote therapeutic monitoring (RTM) and the ongoing public health emergency (PHE). The 2024 final rule allows private practice physical therapists (PTPPs) and occupational therapists in private practice (OTPPs) to employ general supervision for assistants using RTM services. This flexibility extends through the end of 2024, prompting discussions about the potential extension to traditional therapy services in brick-and-mortar clinics.

Recognition for Caregiver Training

CMS acknowledges the significance of caregiver training and introduces five new CPT codes to facilitate reimbursement for caregiver training services under a therapy plan of care. These services, designed to achieve desired patient outcomes, cover a range of activities without the patient present. Rehab therapists now have the opportunity to bill for caregiver training, emphasizing the importance of involving family members, friends, or neighbors in the rehabilitation process.

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Telehealth Perseveres

Telehealth services continue to be a notable feature in the CMS landscape. Despite calls to elevate PT, OT, and SLP services to category one or two telehealth distinctions, CMS maintains outpatient rehab services at the category three level. However, a temporary extension through the end of CY 2024, granted by the Consolidated Appropriations Act of 2023, allows rehab therapy to maintain its telehealth momentum. Ongoing commentary and research submissions remain essential to advocate for a more permanent integration of telehealth services for rehab therapists.

Clarity on Place of Service (POS) Codes

In addressing persistent confusion, CMS clarifies the application of place of service (POS) codes when billing for telehealth services. Distant site practitioners in PT, OT, and SLP are instructed to apply modifier 95 to identify telehealth services, with payments continuing at the non-facility rate until the end of CY 2024. Further nuances in payment rates based on POS codes emphasize the importance of accurate coding for optimal reimbursement.

MIPS Updates for PTs, OTs, and SLPs

The Merit-based Incentive Payment System (MIPS) will undergo significant changes in 2024. While the performance threshold remains at 75 points, PTs, OTs, and SLPs will no longer experience automatic reweighing of the Promoting Interoperability category. The weight distribution for those reporting all four types includes Quality (30%), Cost (30%), Promoting Interoperability (25%), and Improvement Activities (15%). PTs and OTs, exempt from reporting on the Cost category, see adjustments in their MIPS score calculations.

Specialty Set Evolution

The PT and OT specialty sets witness additions and subtractions in 2024. Noteworthy additions include measures related to cognitive impairment, community service connections, and functioning in individuals with mental and substance use disorders. Simultaneously, specific criteria, such as BMI screening and follow-up plans, are removed. Providers are advised to stay informed about introducing CQM 505, focusing on gains in Patient Activation Measures (PAM) Scores at 12 months, although not directly related to rehab therapy.

Introduction of the Musculoskeletal MIPS Value Pathway (MVP)

A significant highlight for rehab therapists is the introduction of the Musculoskeletal (MSK) MIPS Value Pathway (MVP) in 2024. This pathway encompasses quality measures, improvement activities, and a cost measure specifically tailored for musculoskeletal care. PTs, OTs, and SLPs participating in MIPS can expect measures targeting functional status changes for various impairments, fall prevention, and screening for social drivers of health. However, concerns arise about the reliance on specific criteria that may not be universally accessible to physical therapists, prompting CMS to address these issues and provide alternatives.

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