AOTA Advocacy to Update Personnel Qualifications in the Proposed Medicare Physician Fee Schedule Rule
AOTA submitted detailed comments (See “Related Content” in the column at right) to the Centers for Medicare and Medicaid Services (CMS) addressing policy issues in the proposed rule on the Medicare Physician Fee Schedule (MPFS) including therapy qualifications and requirements; the outpatient therapy cap limits; physician quality reporting; physician self-referral; and comprehensive outpatient rehabilitation facility issues.
In particular, AOTA has been advocating for years for CMS to revise the therapy personnel qualifications at 42 C.F.R.§ 484.4 because these regulations have been outdated for decades.
AOTA was pleased to see CMS respond by updating the archaic requirements in its proposal, but AOTA asserted that the qualifications could be clarified and simplified even more. AOTA responded to the complex proposed rule by requesting more clear and straightforward qualifications for occupational therapists, occupational therapy assistants, and foreign-trained practitioners. AOTA emphasized the importance of linking personnel qualifications to state regulatory requirements.
Additionally, AOTA has been an active participant in developing quality measures for the PQRI (Physician Quality Reporting Initiative) program, and continues to work with member experts on measure development. PQRI provides a 1.5% lump sum bonus incentive payment to occupational therapists that voluntarily report on quality measures performed as part of their service provision and submitted to their Part B Medicare contractor. In 2007, for example, occupational therapists can report the Screening for Future Fall Risk measure.
In its MPFS comments, AOTA also requested that CMS open up additional measures to occupational therapy reporting in 2008. These measures include:
- Documentation of Current Medications in the Medical Record
- Patient Co-Development of Plan of Care
- Pain Assessment Prior to Initiation of Patient Treatment
- Plan of Care for Urinary Incontinence in Woman Aged 65 Years and Older
- Osteoporosis: Communication with the Physician Managing Ongoing Care Post Fracture
- Stroke and Stroke Rehabilitation: Screening for Dysphagia
- Cataracts: Assessment of Visual Functional Status
- Universal Weight Screening (BMI)
- Screening for Clinical Depression
- Screening for Cognitive Impairment.
AOTA continues to work closely on this initiative with the CMS contractor Quality Insights of Pennsylvania and the American Medical Association.