AOTA Continues Its Advocacy Efforts to Address Recent OTA Reimbursement Provisions

Since the passage of the Bipartisan Budget Act of 2018 (BBA18) last February, AOTA Public Affairs Division has been working on interpreting and advocating about the new requirements concerning occupational therapy assistant (OTA) services. The BBA made significant changes to payment for OTA-provided services under Medicare Part B that will become effective in 2022, basically cutting payment by 15%. In addition, a modifier identifying which services are fully provided by an OT or if they are provided “in whole or in part,” as the legislative language states, by an OTA will be established by 2019 and implemented by 2020. This concerning change may have multiple effects, which AOTA is analyzing, addressing, and advocating to change.

AOTA is taking a number of steps to ensure that the effects of this provision are understood by the occupational therapy community as well as policymakers. AOTA is working on the following:

• After the publication of the Medicare Physician Fee Schedule proposed rule, AOTA regulatory staff are analyzing, developing alternatives, and preparing questions to submit to the Centers for Medicare & Medicaid Services (CMS) by the comment period deadline of September 10. Read more about the proposed rule.
• Regulatory staff, in collaboration with APTA, are seeking to meet with CMS to discuss the restrictive nature of the proposed OTA regulations on payment.
• On Capitol Hill, federal staff have been educating Members of Congress about the new law as well as working to obtain a study of the consequences of the payment change to the occupational therapy field and Medicare beneficiaries. Again, working with APTA, federal staff are preparing a request for a full government study of the potential impacts for beneficiaries in rural or other underserved areas as a result of the OTA payment change. The goal is to determine if this policy could restrict access to therapy services and thus cause negative health consequences or even increased expenditures for Medicare.
• To expand internal work on this critical issue throughout the organization, a staff group is being convened specifically to discuss policy issues, practice issues, and implement strategies to reach out to members for feedback and advocacy around the payment change. The first meeting is Monday, July 30.

If you have thoughts, concerns, or questions about the OTA issue, use CommunOT to discuss with other members or contact AOTA’s Public Affairs Division at regulatory@aota.org.

To review what the BBA of 2018 did, read AOTA’s FAQs.

We will continue to post updates on AOTA’s website.