Request input CMS policy please

[Guest guest]

I recently was informed that I am on the STATS Policy Workgroup nominated by

several colleagues. STATS is the Short Term Alternatives for Therapy Services

(STATS) contract by the Centers for Medicare and Medicaid Services (CMS) to

perform follow-on claims analysis and to work with outpatient therapy

stakeholders to develop recommendations for improving outpatient therapy payment

policy in the short-term. There are 2 workgroups-Policy and Clinical. There are

several PT's, OT's, and SLP in the workgroups.

The mission of the STATS Policy Workgroup is as follows:

- Evaluate existing payment policy (not limited to existing outpatient

therapy policy).

- Identify specific policy applications that could reduce barriers to the

efficient/effective delivery of medically necessary services.

- Identify specific policy applications to increase confidence that

medically necessary services are being delivered.

The project is roughly 2 years and is very committed to not only productive

dialogue but transparency as well. I have received permission to publish this

and to seek suggestions and recommendations directly by you and I assure you

that these suggestions once consolidated will be forwarded as appropriate.

Per the director of the STATS workgroup, a chief constraint of our activities

will be to discuss policy options that are realistically achievable in the

short-term. For example, some changes in Medicare Manual language and some

coding changes, if appropriate, can be achieved in relative short periods, while

complex changes to CMS payment systems or forms may take extended periods of

time. We are not seeking to develop a new instrument or to validate an existing

tool as other CMS contracts serve those longer-term analyses. However, among

several options, we are considering if it is feasible that existing processes

being used by clinicians could be used in a new short-term policy to help

describe clinical need and/or progress on the claim form through the

introduction of new codes that could serve to describe clinical information

(e.g. severity, progress, or outcome). The proposed introduction of such

information may have policy implications within the scope of CMS activities

(e.g. Medicare Manual language and regulations) to those beyond the direct scope

of CMS control (e.g. Social Security Act or CPT-4 and ICD-9 coding development).

This workgroup will help inform CSC of policy variables to consider, as well as

policy barriers that need to be addressed in order for proposed options to be

considered viable.

Time constraints may be the largest barriers to some potentially good

suggestions. As the project proceeds, it will begin to focus in on the most

realistic options and begin to address the details of what would need to be

addressed for those option(s) to be realized.

Here is your assignment! Prior to Jan 4, please comment directly on this blog

or to me at larry@... the

following:

What are the top 5 most achievable short term policy options that help

better identify patient need for therapy and/or measure progress/outcome?

Your feedback and input is greatly appreciated.

Happy Holidays!

larry@...

__________________________________________

Larry

Larry Benz PT, DPT

PT Development LLC

13000 Equity Place Suite 105

Louisville, KY 40223

larry@...

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that none of us reads or understands if often contained here.