American Physical Therapy Association
YOUR VOICE MATTERS:Individual advocacy by PTs and PTAs matter. Federal agencies are obligated to consider every comment letter written to them and are more likely to listen when more people are echoing the same concerns. Please join us in our advocacy by submitting your comments today!HOW TO SUBMIT YOUR LETTER:We suggest you submit comments on the CY 2021 Home Health PPS proposed rule electronically, on the website: comment?D=CMS-2020-0077-0002.Copy and paste your introductory paragraph into the comment box and upload this document as a file, which you can do below the comment box on the website. ** REMINDER: DELETE THESE SUBMISSION INSTRUCTIONS PRIOR TO SUBMITTING YOUR COMMENTS _______________________________________________________________________[MONTH & DAY], 2020Seema Verma, MPHAdministrator Centers for Medicare and Medicaid Services Department of Health and Human Services Room 445-GAttn: CMS-1730-PHubert Humphrey Building 200 Independence Ave, S.W. Washington, DC 20201 Submitted electronically RE: Medicare and Medicaid Programs; CY 2021 Home Health Prospective Payment System Rate Update; Home Health Quality Reporting Requirements; and Home Infusion Therapy Services RequirementsDear Administrator Verma: I am writing in response to the request for comments on the Centers for Medicare and Medicaid Services’ Calendar Year 2021 Home Health Prospective Payment System Rate Update proposed rule.[INTRODUCTORY PARAGRAPH: INSERT A PARAGRAPH ABOUT YOURSELF, THE PHYSICAL THERAPIST SERVICES YOU PROVIDE, YOUR PRACTICE SETTING, AND THE PATIENTS YOU SERVE; OR YOUR STATUS AS A STUDENT AND AMBITIONS AFTER GRADUATION.]As a [PHYSICAL THERAPIST/PHYSICAL THERAPIST ASSISTANT/PHYSICAL THERAPY STUDENT], I appreciate the opportunity to provide feedback to CMS on the proposals included within the home health PPS rule. I respectfully request that you consider my more detailed comments and recommendations provided below. [BELOW ARE SUGGESTED COMMENTS TO SUBMIT TO CMS. FEEL FREE TO ADD COMMENTS ON OTHER PROPOSALS WITHIN THE RULE. DELETE ANYTHING YOU WISH TO EXCLUDE.]The Use of Technology Under the Medicare Home Health BenefitI appreciate CMS’ actions to make permanent the new flexibilities provided by the COVID-19 PHE Interim Final Rule with Comment Period (85 FR 19230), allowing the use of telecommunications technology included as part of the home health plan of care as long as the use of such technology does not substitute for in-person visits. I also support CMS’ proposal to allow a broader use of telecommunications technology to be reported as an allowable administrative cost on the cost report.However, because these services cannot substitute for a home visit ordered as part of the plan of care and cannot be considered a home visit for the purposes of patient eligibility or payment, the new flexibilities will be of little benefit to HHAs and the millions of Medicare beneficiaries they serve. The COVID-19 pandemic has highlighted areas of the American health care system that clearly need modernization. Many services can be safely and effectively delivered remotely, and policy and payment systems should encourage their use. However, when these services, and the technology being used to deliver them, are not reimbursed, providing them becomes administratively and financially infeasible. This forces providers to risk their own safety and the safety of their patients to meet their bottom line. While many services can and should only be delivered in person, I strongly encourage CMS to work with Congress to amend Social Security Act Section 1895(e)(1)(A) to allow payment for services furnished via a telecommunications system when those services substitute for in-person home health services ordered as part of a plan of care.CY 2021 Home Health PPS Rate UpdateI support CMS’ proposal to increase aggregate payments in CY 2021 by 2.6%. However, due to the increased demand on the home health industry as a result of the COVID-19 pandemic, as well as the lack of coverage for home health services delivered remotely, I strongly encourage CMS implement a larger increase. Patients are safest at home during a pandemic, and home health providers risk their own safety to ensure that these patients continue to receive quality care with minimum exposure. HHAs should be adequately reimbursed.Flexibility for Physical Therapists to Perform Initial and Comprehensive Assessment in Home Health When Nursing and Therapy Are OrderedI appreciate that CMS has temporarily granted physical therapists authority to perform initial and comprehensive assessments in home health when nursing and therapy are ordered during the COVID-19 public health emergency. The pandemic has shed light on numerous areas of the health care in need of modernizing. Because the vast number of home health referrals are for physical therapy, along with nursing, this modification is practical. Expanding the category of providers who may perform initial and comprehensive assessments to include physical therapists will provide home health agencies with additional flexibility that may decrease patient wait times for initiating home health services and relieve pressure on provider types that may be stretched too thin. Moreover, the needs of the patient should determine which provider type is most appropriate to complete the assessment. I therefore encourage CMS to permanently allow physical therapists to perform the initial and comprehensive assessment in the home health setting when nursing and therapy are ordered.Permanently Authorize Physical Therapist Assistants to Perform Maintenance Therapy Across Settings Under Both Medicare Part A and Part BUnder current permanent regulations, physical therapist assistants are allowed to furnish maintenance therapy in the SNF and home health settings under Medicare Part A. I appreciate that CMS also has temporarily allowed physical therapist assistants to perform maintenance therapy under Part B during the COVID-19 public health emergency. Apart from the expected outcomes and goals of treatment, skilled maintenance therapy is not different from skilled restorative therapy. The physical therapist is professionally trained to oversee and direct a patient’s course of care, and to assign responsibilities to the assistant as clinically appropriate. Moreover, the qualified therapist determines whether it is clinically appropriate for the therapist assistant to perform maintenance therapy. Allowing physical therapist assistants to perform maintenance therapy across settings would promote regulatory alignment and afford providers more latitude in resource utilization. Accordingly, I encourage CMS to permanently allow physical therapist assistants to furnish maintenance therapy under Medicare Part B across settings. Need for Greater Recognition of the Role of Physical Therapists and Physical Therapist Assistants I encourage CMS to reconsider the role of the physical therapist in the provision of home health services. Too often, physical therapists and physical therapist assistants are seen by policy makers as only providing a small number of interventions directly to patients. In reality, physical therapists and physical therapist assistants provide a wide scope of services in addition to the traditional interventions commonly associated with the profession. In addition to providing treatment interventions that include manual therapy, gait training, and therapeutic exercise, physical therapists and physical therapist assistants also provide patient and professional health-related education, pain management, incontinence treatment, wound care, neuropathy treatment, and medication management, in addition to spending countless hours on documentation. Despite this, payment models usually only consider the more “common” types of physical therapy when determining payment. Further exacerbating the issue is the lack of physical therapists in oversight positions, as most case managers are nurses, often without extensive knowledge of the complex duties and responsibilities of the PTs and PTAs they oversee. I therefore encourage CMS to take a closer look at the contributions of physical therapists and physical therapist assistants in the home health setting. CMS must ensure that current and future payment models are designed to afford adequate authority and reimbursement based on the quantity and quality of care physical therapists and physical therapist assistants deliver to patients and the greater health care system.Additional Comments[ADD ANY ADDITIONAL COMMENTS OR ISSUES YOU WOULD LIKE TO BRING TO CMS’S ATTENTION HERE. OTHERWISE DELETE THIS SECTION.]ConclusionThank you for the opportunity to comment on the CY 2021 Home Health PPS proposed rule. Thank you for your consideration.Sincerely, [NAME][TITLE] ................
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