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OT, CPA, Esq.
Tuesday November 20, 2012


SAN DIEGO — "You almost have to be an accountant to provide care," said Timothy M. Mullen, OTR, PhD, CHT, director of legislative and reimbursement division of the American Society of Hand Therapists. "And an attorney," he added, as he explained the latest regulations governing the profession to an audience at the ASHT annual meeting, held here in October.

As the healthcare market lurches into a new era under the Affordable Care Act, while still carrying the baggage from previous attempts to fix the troubled system, individual practitioners face a shifting maze of hurdles and hoops coming via the U.S. Centers for Medicare & Medicaid Services.

Audience members complained of surprise visits from CMS inspectors and routinely returned reimbursement claims as they try to figure out how to come into line with all that is required of them. "Itís almost as if youíre guilty until proven innocent," one therapist said.

Mullen provided an overview of some key points, but his overall advice was to stay vigilant and active during the change process, networking with other practitioners and legislators. "Using your patients to advocate for you is one of the strongest tools you have," he added.

Mullen said the move to Accountable Care Organizations, "worries me more than a lot of things." The consolidation concept seems to drive care towards big hospital systems, he said. "My concern is whatís going to be given up."

Gayle Lee, JD, the American Physical Therapy Associationís director of federal payment policy and regulatory affairs, who participated in the session's panel, advised therapists to be proactive in this area and reach out to local ACOs for referrals. "The key is be aware of what is happening in your community," she said. "Let them know what you can do for them. That would put you in a better position."

Another issue for Mullen is the competitive bidding process for off-the-shelf durable medical equipment slated to take effect soon. "My concern is that it drives the prices down for all of us," he said.

Mullen said he also is worried about the push toward prefabricated orthotics on the whole. "If we lose the ability to make stuff, weíre giving away our profession," he said. "The L-code is the same, but the fitís not there."

The 2013 proposed fee schedule with therapy caps set at arbitrary limits are worrisome, Mullen said. "Itís hard for us to make a living off of what might and might not be," he said. "My biggest concern is it puts government between the healthcare provider and the patient."

For the ACA on the whole, the jury still is out, Mullen said. "The biggest thing we should notice is more people have access to our care," he said. "Some of it has to play out yet."

Documentation is key throughout this transition and in these overall fiscally difficult times, the panelists said. "Weíre in an environment where documentation has to be really stellar," Lee said.

Signatures are increasingly important, the panelists said. Be sure to have a physician review and sign all plans of care, and be sure patients sign acknowledgements when they receive DME devices, they said. "If you donít have that in your files, it never happened," Mullen said. Spell out return policies for DME devices, such as 30 days for manufacturer defect, so patients don't return the devices when they receive bills for them, he added.

Physicians also need to sign off on specific medical equipment, Mullen said. "A scrip that says 'splint as neededí is pretty much useless," he said. "Those days are over."

The Office of the Inspector General creates a new blueprint every year, Mullen said. "Basically, theyíre out to prevent fraud and abuse," he said. "If you bill different from the average, they sort of target you."

There are 15 regional Medicare Administrative Contractors across the country, and they apply the rules differently, Mullen said. "Remember — nothing is automatic. Youíve got to do something in order to keep getting paid. You need to work more closely with your [contractor] to figure out what it is."

The Physician Quality Reporting System will be applied to occupational and physical therapists in the coming years with a system of incentives and penalties, starting with a bonus of 0.5% for compliance in 2013. "You have to prove yourself next year so they donít penalize you," Mullen said. "We have to think in terms of injury prevention and so-on and so-forth."

An electronic health record program that helps guide you through the implementation of new ICD-10 coding is the best approach, Mullen said. "Youíll be in better shape. Everywhere else in the world seems to have adopted it very nicely and we havenít yet."

Adding to the burden, CMS plans to collect functional data in 2013 through a series of "G codes," which have yet to be fully sorted out.

Christina Metzler, the American Occupational Therapy Associationís chief public affairs officer, redirected the audience, urging them to seek solace in the light at the end of the tunnel. "Itís a pain, but we have to think beyond the pain. We have to do these things to preserve access to therapy — period," she said. "Things are changing, and weíre going to work to make them change for our benefit and the benefit of our clients."

Natasha Emmons is editor.

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Tuesday November 20, 2012
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