What Does the End of the PHE Mean for Occupational Therapy?
What the Proposed Changes Could Mean for OT
According to CMS data highlighted in the proposed rule, including simulated data for 2018, the utilization of visits per 30-day periods of care for all disciplines (skilled nursing PT, OT, SLP, home health aide, social worker) declined from 9.86 in 2018 to 8.00 in 2023. OT visit utilization declined from 1.02 visits per 30-day period in 2018 to 0.76 visits per 30-day period in 2023.
AOTA is concerned that the proposed payment cut may further reduce the utilization of OT services and patient access to medically necessary OT services. Since the adoption of PDGM, AOTA has heard from numerous OTs and OTAs about PDGM’s negative impact on their ability to treat HH patients who need their services. These reports include that agencies are pressuring therapists to reduce the number of visits, including OT visits, and that agencies are using algorithms to determine how many therapy visits to allow based on diagnosis and not relying on the therapist’s clinical judgment.
On the other hand, we believe that CMS has listened to AOTA’s concerns about the barriers that can make it challenging for OT practitioners to deliver medically necessary skilled OT services to Medicare Part A home health beneficiaries. CMS’ proposed changes to the CoPs could help ease delays and obstacles for patients seeking home health services, including OT services.
AOTA continues to communicate our concerns and recommendations to CMS and encourages practitioners to share their experiences, and the impact on patient care with CMS. We are developing written comments to CMS expressing our concerns with the proposed rule and input on OT’s role in quality measures and as a key member of the care team, and we will keep urging CMS to adopt safeguards to protect patient access to medically necessary OT services. It is imperative that agencies rely on the therapist’s clinical judgment to determine the type and amount of therapy services that an individual patient needs.
Comments on the HH PPS proposed rule are due August 26, 2024. CMS typically releases the final HH PPS rule in early November – watch for AOTA updates. If you have questions, please email regulatory@aota.org.
Tell CMS How the Proposed HH Changes Could Impact YOU
Join your colleagues in submitting comments to CMS online by August 26. Go to the Federal Register and enter your comments in the Comment field. We encourage you to share your own concerns and specific examples of how the proposed changes could impact you and your patients. If you have input to share about the above issues, tell CMS. It is critical that CMS hears from OT practitioners about the potential effect on patient access to OT services.