Joe,
 
re: legislation to allow ATs to bill for therapy under Medicare
 
We are working against this legislation. See:
http://capwiz.com/aota/issues/alert/?alertid=9424141&type=CO
 
Chuck
 
Action Alert    
Oppose Legislation Permitting "Incident-to" Billing for Therapy Services by 
Non-Qualified Therapists: 
Protect Occupational Therapy's Scope of Practice        
        

History:


The Access to Physical Medicine and Rehabilitation Services Improvement Act was 
introduced in the 109th Congress. Legislators in the Senate and House of 
Representatives are now debating introducing this legislation for the 110th 
Congress. This legislation would allow non-qualified therapists to bill the 
Medicare program for therapy services "incident-to" the physician's 
professional services, thereby eroding the May 2005 Centers for Medicare and 
Medicaid Services (CMS) regulations that restrict the billing of therapy 
services under Medicare to those qualified to deliver physical therapy, 
occupational therapy, and speech language pathology services. This legislation 
would allow the billing of services provided by athletic trainers and 
lymphedema services at 80% of the physician fee schedule and would apply the 
therapy cap limitations to these services. 

In the 2005 Medicare Physician Fee Scheduled rule, CMS determined that 
occupational therapy services provided in a physician's office incident to a 
physician's professional services be furnished by personnel who meet certain 
standards. This rule meets the intent of Section 4541(b) as passed by Congress 
in the Balanced Budget Act of 1997. The rule established qualifications and 
clinical preparation standards for those providing "incident to" occupational 
therapy services, implementing the requirements adopted by Congress in 1997 
which were designed to protect patient safety, ensure the appropriate use of 
Medicare resources, and guarantee the delivery of occupational therapy services 
by qualified occupational therapists.

In the past, a number of provider groups (i.e., athletic trainers, massage 
therapists, low-vision specialists, and others) have been paid "incident to" 
occupational therapy services. Since CMS published this rule, these provider 
groups have formed a coalition 
<http://www.coalitiontopreservepatientaccess.org/> to support reversing the 
changes outlined in the "incident to" rule legislatively. 


AOTA's Position:


AOTA strongly supports Medicare's qualifications standards. Services reimbursed 
as occupational therapy should be provided by an occupational therapists or an 
occupational therapy assistant under the supervision of an occupational 
therapist. 

AOTA has monitored the issue closely and will continue to work with all members 
of Congress to uphold the intent of Section 4541(b) in the Balanced Budget Act 
of 1997. This legislation, and the corresponding rule by CMS, eliminates the 
abuse of nonqualified individuals providing services that were billed to the 
Medicare program, and ultimately will help protect the scope of occupational 
therapy and ensure beneficiaries that the services they receive are of the 
highest possible quality. 


Action Needed:


In order to ensure that this legislation does not gain any traction, contact 
your Representatives (one member of the House of Representatives and 2 
Senators) to urge their opposition to this legislative issue. If you have any 
questions, please contact the AOTA Federal Affairs Department at [EMAIL 
PROTECTED] or 1-800-SAY-AOTA.

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