My name is Katie Baratta and I just graduated from the Regis University School of Physical Therapy. I had the opportunity to spend two weeks at the APTA doing a student internship. I was able to talk to many different members of the APTA, attend the Federal Advocacy Forum, and learn more about what the APTA has been doing to move our profession forward. I’ve written a series of essays about my experiences here at the Association.
Interview with Lindsay Still, Senior Payment Specialist
I talked with Lindsay Still, a Senior Payment Specialist, and she explained the current state of the PTCPS. Read a summary of our interview below!
The Physical Therapy Classification and Payment System (PTCPS) is an ongoing initiative that was developed as an alternative to the current, fee-for-service codes—ones that easily fail to capture the true value of what PTs do—and instead particularly account for the complexity and skill of clinical expertise required for patients with more involved presentations. It also incorporates the use of standardized outcome measures. PTCPS would include a single CPT (Current Procedural Technology) code for the entire treatment session versus the assortment of 15-minute unit codes that we’re used to today.
The system has gone through multiple iterations in the past several years, and was developed by the APTA in collaboration with a specialty work group within the AMA (American Medical Association) involving members from the professional organizations of OTs, massage therapists, athletic trainers, speech-language pathologists, chiropractors, psychologists, optometrists, podiatrists, physiatrists, neurologists, orthopedic surgeons, osteopathic physicians, and representatives of CMS (Centers for Medicare & Medicaid Services).
Structure of the new coding system
Under the new system, there would be three new evaluation codes that puts a patient into an initial category of lower, moderate, or higher complexity. Certain documentation criteria (e.g. under patient history, presentation, or plan of care) would determine which of the three eval codes you would select. For example, the number of comorbidities for a given patient would play a role in the eval code selection. There would also be a single code for any re-eval visit.
As currently structured, the proposed PTCPS would also incorporate five treatment codes, based on the overall complexity of the patient’s presentation and treatments. These codes, much like our current CPT code for evals (97001 Physical Therapy Evaluation), would not have a set time frame or number of units associated with it. However, treatment billed under the lowest complexity code would likely be much shorter than a treatment session under the highest complexity code, and the reimbursements would reflect this fact.
In 2014, pilot testing of the new system was performed with PTs using the new system to code/bill for hypothetical patients, as well as using the new system to code the treatments of actual patients previously coded with the existing system. This testing occurred in various care settings. Overall, the clinicians were very consistent in their ability to categorize patients with the new initial eval codes. However, for the intervention codes, the pilot clinicians were only able to consistently categorize those patients with the least complex and most complex presentations. There was significant disagreement between PTs in regards to cases that fell within the different “moderate” treatment categories.
The definitions and valuation of the proposed eval codes were reviewed and approved by the RUC (Relative Value Scale Update Committee) and will now require CMS approval. Lindsay is hopeful that CMS will accept the new eval codes, as they will be budget-neutral. In August of 2016, CMS will release the 2017 Medicare Physician Fee Schedule Final Rule; this should include the new PT evaluation and reevaluation codes. The new codes will go live on January 1, 2017. PTs will have three brand-new CPT codes to replace the current 97001 Physical Therapy Evaluation. The APTA will provide training and support to clinicians during the time leading up to the release of the new eval codes.
Impediments to the impending treatment code change
The new treatment codes will require further review and refinement, given their inconsistency of use during the pilot testing. This will likely be an interactive process, and not without controversy from the perspective of payers (insurance companies). In the meantime, the RUC has requested a “backup plan” to address ten CPT codes commonly used by PTs which have been identified as “potentially misvalued codes,” most of which PTs probably use frequently:
- 97032 attended electrical stimulation
- 97035 ultrasound
- 97110 therapeutic exercise
- 97112 neuromuscular reeducation
- 97113 aquatic therapy with therapeutic exercise
- 97116 gait training
- 97140 manual therapy
- 97530 therapeutic activities
- 97535 self care home management training
- G0283 unattended electrical stimulation (non-wound)
These codes are flagged because they represent a high reimbursement rate and have not been assessed since 1994.
As a result, the APTA is currently redirecting efforts to provide replacements to those 10 codes rather than waiting for the codes to be reevaluated for us. The new treatment codes the APTA envisions to replace them with would be procedure-based: you would still bill in 15-minute increments. However, they would be streamlined; there would be fewer codes, and the codes would reflect the types of treatment PTs currently perform in practice (as opposed to focusing on what treatments PTs may have historically performed).
Future of the proposed treatment codes
The more general patient- and value-based treatment codes initially envisioned by the APTA are still in the works, but Lindsay foresees a longer process before fruition: it will require all parties to agree on a coding system that accurately and cost-effectively describes the type of treatments that PTs perform for patients. This includes the third-party payers who generally prefer the current setup of treatment codes based on billable units. The current coding system is easy to monitor for abuse or overuse of treatments.
I asked Lindsay if she saw outcome measures as one way of giving insurance companies some power to track the value of treatments under the proposed system. While they wouldn’t be able to screen specific procedures in the same way that they are able to under the current system, they would be able to, for example, monitor whether the progress of a “low complexity” patient was lagging behind what would be expected given that patient’s presentation.
She agreed that this could work in theory, but felt that we still have a long way to go in terms of standardization of outcome data across the spectrum of patient presentation. This is one of the reasons the PT Outcomes Registry will be so important! These two issues truly are intertwined in the future of value-based billing for PT services.