AMRPA Urges CMS to Avoid Budget Neutrality Cuts to Vital Care Services
Association issues comments on CY 2021 Physician Fee Schedule with recommendations to maintain patient access to needed care, especially given long-term rehabilitation needs of those recovering from COVID-19
(WASHINGTON – October 7, 2020) – In a comment letter submitted on October 5 to the Centers for Medicare and Medicaid Services (CMS) regarding its proposal to continue with its changes to the Physician Fee Schedule (PFS), the American Medical Rehabilitation Providers Association (AMRPA) expressed concerns with budget neutrality cuts to services that could negatively affect access to rehabilitative care for Medicare beneficiaries.
In its letter, AMRPA confirms its support of a related provision in the fee schedule – the updating of the value outpatient evaluation and management (E/M) visit codes – but reiterates a position taken previously in response to last year’s PFS proposed rule that this update be made only while avoiding cuts to other vital services.
CMS estimates place payment reductions at 9% for critical rehabilitation services, such as outpatient physical and occupational therapy services, and at approximately 10% for commonly billed physician services in inpatient rehabilitation facilities (IRFs) and other hospitals.
While the payment cuts will decrease provider compensation, primarily of concern to AMRPA is the impact this will have on the quality of treatment for patients.
“Cuts to these services lines will exacerbate an already tenuous access situation, likely harming already-vulnerable beneficiaries. Further, the reduction in reimbursement would come at a particular inauspicious time, right as front-line providers are facing a potential second wave of COVID-19,” says AMRPA in its letter.
While recognizing statutory restraints on CMS in terms the PFS budget neutrality requirements, AMRPA also suggests a number of potential actions to avoid the cuts and negate the adverse impact of the current proposal. Among those actions are waiving the budget neutrality factor applied to the fee schedule using public health emergency (PHE) discretionary authority, lowering the amount by which outpatient E/M codes are raised, phasing in the increase gradually and delaying the availability of an E/M add-on code.
Throughout its comments to CMS, the association underscored the crucial role that IRFs play in patient recovery, saying, “The hallmark of IRF care is a multi-disciplinary team approach to care, combining physician medical management with multiple therapy disciplines and often numerous other specialties of care, such as psychological services.
“The need for these multiple therapy disciplines does not cease once the patient leaves the hospital. Many IRF patients need long-term physical, occupational, speech and other therapies to continue to recover from their injury or illness after leaving the hospital.”
AMRPA’s comments also emphasize the need to continue the expansion of telehealth rehabilitation services, particularly as COVID-19 persists in communities across the country. The availability to access these services remotely has proved crucial to patients and their ability to continue treatment and avoid unnecessary risks of exposure.
The full text of AMRPA’s comment letter in response to the CY 2021 Physician Fee Schedule is available on the association’s website.
View the association’s past advocacy efforts on behalf of its members.
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American Medical Rehabilitation Providers Association
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