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CMS Presents Reports on Therapy Outpatient Payment Recommendations

ASHA and other therapy organization representatives recently met with

Centers for Medicare and Medicaid Services (CMS) officials and

principal AdvanceMed investigator of the Outpatient Rehabilitation Services

Payment System Evaluation, Ciolek. The purpose of the meeting

was to discuss AdvanceMed's findings and recommendations for creating

a global payment approach for therapy services. The new system would

potentially replace the $1500 Medicare financial limitation or cap.

However, the research is not scheduled to be completed in time for the

December 31, 2005, deadline of the moratorium on the Medicare therapy

caps.

The AdvanceMed reports presented five conclusions:

1. SLP, PT and OT are distinctly different services;

2. CMS has the foundation for analyzing outpatient therapy services

for policy development purposes;

3. A global approach is the most promising immediate approach to

therapy payment policy;

4. Data analysis needs to be supplemented with clinical expertise,

clinical and outcomes research, and expert opinion; and

5. A new prospective payment system will take several years to

develop and implement.

The AdvanceMed global approach would be based on the Medicare

physician fee schedule, eliminate the cap, require ongoing data analysis,

establish reasonable utilization limitations, rely on national

coverage decisions, and use a standardized instrument or three standardized

outpatient therapy patient assessment instruments to describe patient

conditions. A first step in establishing the global approach would be

the testing of a 21-group clinical classification system. An initial

review of the system finds only six of the groups related to

speech-language pathology: communication, mental/cognitive,

neurological-central, swallowing/feeding disorder, systemic, and

general/non-specific impact/other. Conversely, there are nine groups

for musculoskeletal disorders alone.

The reports stress the distinction of speech-language pathology

services from physical therapy and occupational therapy. Fewer SLP

patients were estimated to surpass a three separate cap level than for

PT or OT. SLP had the lowest average annual expenditure per enrollee.

Moreover, the age distribution of SLP patients increased while it

decreased for PT and was relatively constant for OT. SLP services are

only 7% of overall utilization for 2002 claims while physical therapy

is 75% and occupational therapy is 18%. The reports are posted on the

CMS web site at http://www.cms.hhs.gov/medlearn/therapy/.

The CMS reports will also be used by the General Accountability Office

(GAO) in their scheduled report to Congress regarding identifying

conditions or diseases that may justify waiver of the therapy caps and

to identify criteria for such waivers. ASHA is reviewing the studies

and will be submitting comments to CMS and GAO. For more information,

please contact Ingrida Lusis, ASHA's Director of Health Care

Regulatory Advocacy, at ext. 4482, or via e-mail at ilusis@....

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The American Speech-Language-Hearing Association

10801 Rockville Pike

Rockville, MD 20852

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The American Speech-Language-Hearing Association

10801 Rockville Pike

Rockville, MD 20852

Members 1-

Consumers 1-

www.asha.org

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