MSOTA Current News

MSOTA Current News

Download [ Representative Assembly Action ] .PPT file

New contact information for the MS Department of Health, Office of Professional Licensure

Phone Number: 601-364-7360
Fax: 601-364-5057

Physical Address:

143 Lefluer.s Square, Suite B
Jackson, MS 39211

Mailing Address:

P.O. Box 1700
Jackson, MS 39216

www.msdh.state.ms.us

TriAlliance Letter to Members

Important AOTA, APTA, and ASHA Letter to Members

The American Occupational Therapy Association (AOTA), American Physical Therapy Association (APTA), and American Speech-Language-Hearing Association (ASHA) were instrumental in working with both Congress and the Centers for Medicare and Medicaid Services (CMS) in the development of the Medicare Part B cap exceptions process.

Both CMS and Congress are closely monitoring the effectiveness of the exceptions process and whether or not it can be part of a viable therapy cap alternative. We strongly encourage our respective members to exercise the highest standards of judgment, and ethical reasoning in using the exceptions process. This will help to ensure a positive implementation of the process.

Dear Member,

As part of the Deficit Reduction Act of 2005, Congress has mandated that the Centers for Medicare and Medicaid Services (CMS) implement an exceptions process by which beneficiaries could receive medically necessary Medicare Part B rehabilitation services, even if those services exceed the therapy cap amount. In March 2006, CMS provided specific details on the implementation of this process. The American Occupational Therapy Association (AOTA), the American Physical Therapy Association (APTA), and the American Speech-Language-Hearing Association (ASHA) were instrumental in working with both Congress and CMS in the development of the exceptions process. This joint letter is meant to emphasize how important it is for clinicians to exercise the highest standards of judgment and ethical reasoning in using the exceptions process.

Although not a perfect solution to the therapy caps, the exceptions process reinforces existing coverage criteria and recognizes the role of the clinician's judgment as well as the individual beneficiary's needs as components in the determination of the need for therapy under Medicare. The exceptions process emphasizes that the clinician is in charge of determining the duration and intensity of services that the patient needs. By highlighting the responsibility that the individual clinician has to attest that the services meet Medicare coverage criteria, CMS has expressed faith in speech-language pathologists, physical therapists, and occupational therapists to effectively and appropriately manage patient care and provide only those services which, in their professional judgment, are deemed reasonable and necessary.

CMS's emphasis on the clinician's attestation process signals that clinicians must take the determination of need seriously and that documentation is appropriate to justify additional treatment. However, along with this responsibility, clinicians also must make responsible, and at times, difficult decisions about when services are no longer needed. CMS has stated that it does not believe a large number of services should exceed the cap. Studies conducted of past years' services indicate that between 14% and 20% of patients will exceed the cap, with variations for setting and other variables. But once the clinical evaluation and the review of the Medicare coverage criteria (e.g., need for skilled services, potential for improvement) are done by the clinician, CMS's process gives full faith and credit to the clinician's determination. If post-payment reviews are conducted, appropriate documentation is critical in proving that services below or above the cap are reasonable and necessary.

Our Associations are aware that both CMS and Congress are closely monitoring the effectiveness of the exceptions process and whether or not it can be part of a viable therapy cap alternative. Because of the importance of a positive implementation of the exceptions process, AOTA, APTA, and ASHA strongly encourage our respective members to use sound clinical judgment and ensure proper documentation of services. Specifically, we urge members to

Understand and abide by current Medicare coverage guidelines
Ensure that patients receive the care they are entitled to under Medicare
Thoroughly understand the exceptions process and its requirements, including recent changes to documentation requirements to ensure appropriate reporting of services
Review and abide by their respective codes of ethics and related documents in providing only those services that will benefit their patients
Recognize when care is no longer covered by Medicare

Physical therapists, occupational therapists, and speech-language pathologists are highly trained, qualified professionals who must use the highest level of skill and competence to wisely, efficiently, and effectively manage patients and make appropriate decisions regarding their care.

Sincerely,
M. Carolyn Baum
President, AOTA

Alex Johnson
President, ASHA

R. Scott Ward
President, APTA

The American Occupational Therapy Association
4720 Montgomery Lane
Bethesda, MD 20814
Phone 301-652-6611 - Fax 301-652-7711 - TDD 800-377-8555
www.aota.org

HSM - HealthSystems of Mississippi

Revisions to the Medicaid Outpatient Physical, Occupational, and Speech Therapy Policies

In response to your feedback and in an effort to better serve therapy providers, the Division of Medical (DOM) has made revisions to the Outpatient Physical, Occupational, and Speech Therapy Policies. The policy changes will be effective July 1, 2006.

The following changes in the DOM therapy policies are summarized for your convenience.

Exclusions (Section 47.03, 48.03, 49.03)

Some examples have been added to help clarify specific exclusions.

Verbal Orders on the Plan of Care (Sections 47.04, 47.10, 47.12, 48.04, 48.10, 48.12, 49.04, 49.10, 49.12)

Providers will have thirty (30) calendar days to have verbal orders on the Plan of Care signed and dated by the prescribing provider.

This applies to both the initial and the revised Plans of Care.

Evaluation and Treatment on Same Day (Sections 47.09, 48.09, 49.09)

The initial evaluation and the first therapy session should not be done on the same day; however, HSM is authorized to accept retrospective requests for the following exceptions:

Urgent Services

Same Day/Non-Urgent Services � Must follow HSM guidelines for submitting urgent certification requests.

Projected Period of Treatment (Sections 47.10, 47.12, 48.10, 48.12, 49.10, 49.12)

Plan of Care may be developed to cover a period of treatment up to 6 months.

The DOM policy changes noted above have necessitated appropriate changes to the HSM forms. To access the revised HSM forms, go the HSM Web site www.hsom.org under "Publications." If you are unable to download and/or access the information needed via HSM�s Web site and need a hard copy, please submit a written request on company letterhead that includes the Medicaid providers number to HSM at (601) 360-4967.

To access the revised policy, go to the Division of Medical Web site at www.dom.state.ms.us under "Provider Manuals". Please replace your current DOM policy version with the revised policy.

If you have questions about these revisions, please call the HSM Help-line for assistance Monday through Friday 8:00 a.m. to 5:00 p.m. at (866) 740-2221. If you are in the Jackson metropolitan area, please call the HSM Help-line at (601) 360-4949.