June 21, Harry Feliciano, MD, MPH Senior Medical Director Part A Policy Palmetto GBA PO Box (JM) AG-275 Columbia, SC 29202
|
|
- Ross Lang
- 5 years ago
- Views:
Transcription
1 June 21, 2018 Harry Feliciano, MD, MPH Senior Medical Director Part A Policy Palmetto GBA PO Box (JM) AG-275 Columbia, SC Submitted electronically: A.Policy@PalmettoGBA.com RE: Proposed LCD DL37774: Supervised Exercise Therapy for the Treatment of Peripheral Arterial Disease with Symptomatic Lower Extremity Intermittent Claudication Dear Dr. Feliciano: On behalf of our more than 100,000 member physical therapists, physical therapist assistants, and students of physical therapy, the American Physical Therapy Association (APTA) submits the following comments on Palmetto GBA s Draft Local Coverage Determination (LCD) DL37774, Supervised Exercise Therapy (SET) for the Treatment of Peripheral Arterial Disease (PAD) with Symptomatic Lower Extremity Intermittent Claudication. The mission of APTA is to build a community to advance the physical therapy profession to improve the health of society. Physical therapists play a unique role in society in prevention, wellness, fitness, health promotion, and management of disease and disability by serving as a dynamic bridge between health and health services delivery for individuals across the age span. While physical therapists are experts in rehabilitation and habilitation, they also have the expertise and the opportunity to help individuals improve overall health and prevent the need for otherwise avoidable health care services. Physical therapists roles may include education, direct intervention, research, advocacy, and collaborative consultation. These roles are essential to the profession s vision of transforming society by optimizing movement to improve the human experience. APTA fully supports SET, including physical therapy, for Medicare beneficiaries with PAD. Physical therapists are licensed health professionals who evaluate and treat Medicare beneficiaries in a variety of practice settings including private practices, hospitals, skilled nursing facilities (SNF), home health agencies, rehabilitation agencies, and comprehensive outpatient rehabilitation facilities. Within these settings, physical therapists play a vital role in the assessment and management of cardiovascular conditions, as they provide individualized
2 exercise techniques and promote increased function for patients. As a result, we are very interested in the impact this LCD will have on care for Medicare beneficiaries with PAD. Physical therapists evaluate patients needs by gathering data on medical history and other relevant factors such as health habits and comorbidities, and then identify risk factors and behaviors that may impede optimal functioning. The physical therapist s evaluation and subsequent plan of care reflects the chronicity or severity of the current problem, the possibility of multisite or multisystem involvement, the presence of preexisting systemic conditions or diseases, and the stability of the condition. Physical therapists consider the probability of prolonged impairment, activity limitations, and participation restrictions; the living environment; potential discharge destinations; and social support when developing the plan of care. While we reiterate our support for the ability of PAD beneficiaries to receive SET, APTA continues to take issue with several provisions codified in the National Coverage Determination (NCD) 30.35, and now proposed LCD, which refers only to SET in the treatment of PAD in the lower extremities. We also have concerns that several of the SET program requirements included within DL37774 are lacking in clarity, which could lead to seemingly improper payment denials. Pursuant to the Medicare Program Integrity Manual, Chapter 13, Section 13.5, LCDs must be clear and concise and not restrict or conflict with NCDs or coverage provisions in interpretive manuals. 1 As discussed in more detail below, we encourage Palmetto to refine and modify several of the provisions included within the draft LCD. APTA also strongly urges Palmetto to clarify within the LCD and any related policy articles that beneficiaries participating in a SET program are not precluded from receiving additional therapy, such as physical therapy, should they have activity limitations and participation restrictions that may or may not be related to their cardiovascular status (e.g. stroke, congestive heart failure, etc.). Coverage Indications, Limitations, and/or Medical Necessity APTA supports Palmetto s recommendation to use the concepts contained within the World Health Organization s (WHO) International Classification of Functioning, Disability, and Health (ICF) to communicate the patient-centered information describing the symptoms and conditions of each beneficiary and encourages Palmetto to finalize this recommendation. Non-Covered Indications As stated within the NCD, and echoed in Palmetto s LCD, for beneficiaries who have absolute contraindications to exercise, as determined by their primary attending physician, SET for PAD will not be covered. APTA requests that Palmetto clarify within the LCD or related guidance documentation that Palmetto medical review staff would rely upon to determine whether a beneficiary does or does not have absolute contraindications to exercise. APTA is concerned that this language within the policy will be misinterpreted, and could be used as justification to deny SET for beneficiaries who suffer from PAD with symptomatic lower extremity intermittent claudication and who would greatly benefit from therapy. For example, this could be used to deny a SET program even when it is clear that the program is appropriate and would benefit the beneficiary. 1 Medicare Program Integrity Manual, Chapter 13, Section Guidance/Guidance/Manuals/Downloads/pim83c13.pdf Accessed June 13,
3 Assessing Benefits and Harms of Each SET Session APTA requests that Palmetto clarify its proposed policy related to the assessment of benefits and harms of SET. Specifically, we recommend that Palmetto issue guidance on what constitutes an assessment of benefits and harms of SET to ensure providers have an appropriate understanding of the documentation requirements. Qualified Auxiliary Personnel Palmetto references within the draft LCD the NCD s policy on qualified auxiliary personnel, which states that SET must be delivered by qualified auxiliary personnel necessary to ensure benefits exceed harms, and who are trained in exercise therapy for PAD. In clarifying the definition of qualified auxiliary personnel, CMS s SET for PAD Decision Memorandum, dated May 25, 2017, states that while physical therapists are not included in the list of non-physician practitioners, they may participate as qualified auxiliary personnel who may be able to deliver the service. 2 Here, Palmetto s draft LCD includes an additional constraint on the definition of qualified auxiliary personnel, not included within the NCD, stating the auxiliary personnel delivering SET to a given beneficiary must be those providers whose scope of practice, keeping in mind all relevant national and local laws and regulations, includes making the assessments of benefit and risk included in the plan of care for that particular beneficiary. APTA requests that Palmetto delete the second sentence of the Qualified Auxiliary Personnel paragraph included within the draft LCD. The language put forth by CMS in the NCD clearly delineates the types of providers qualified to furnish SET, whereas the draft LCD language is vague, and thus subject to misinterpretation by Palmetto s medical review staff as well as providers, which could constrain the number of providers willing to furnish a SET program for PAD. For example, we presume that when a physical therapist who makes an assessment of benefit and risk included in the plan of care and then directs and supervises a physical therapist assistant in performing elements of the plan of care, this would be in line with the outlined NCD policy. However, due to ambiguity with the language, Palmetto s policy intentions are unclear. Therefore, to ensure beneficiary access to SET is not inappropriately restricted, APTA recommends Palmetto revise its proposed language to mirror the Qualified Auxiliary Personnel definition as referenced in NCD Alternatively, we request that Palmetto clarify its expectations surrounding who may furnish SET in the treatment of PAD in the lower extremities, to better ensure providers, as well as Palmetto medical review staff, understand and correctly apply the policy. Clinicians Responsible for Supervising SET As stated within the NCD, a SET program must be furnished under the direct supervision of a physician, physician assistant (PA), or nurse practitioner/clinical nurse specialist (NP/CNS) who must be trained in both basic and advanced life support techniques. As stated in previous comments, APTA disagrees that the direct supervision of a physician or other non-physician practitioner is necessary for a physical therapist to safely and effectively administer a SET 2 CMS May 25, 2017 Supervised Exercise Therapy Decision Memorandum. rapy&keywordlookup=title&keywordsearchtype=and&list_type=ncd&bc=gaaaacaaqaaa& Accessed June 12,
4 program. The overall effect of requiring this strict supervision level restricted beneficiary access to SET. There is no credible reason for direct supervision by a physician, PA, or NP/CNS when the majority of services that a physical therapist provides do not require such a stringent supervision level. Physical therapists are qualified through education, training, licensure examination, and clinical experience to provide physical therapy services without having a physician onsite, and they do so with great frequency. Physical therapists are sufficiently qualified to furnish SET without the direct supervision of a physician; moreover, physical therapists provide skilled therapy every day across the continuum of care. Therefore, we reiterate our displeasure with requiring physical therapists to be directly supervised when furnishing a SET program and encourage Palmetto to monitor utilization of this therapy in the future to determine whether beneficiary access to SET may be inhibited due to the direct supervision requirement. Components of Treatment APTA appreciates that Palmetto GBA will not stipulate the exercises that may be part of the SET treatment program. We also support Palmetto s statement that the treatment plan should be tailored to the needs of each beneficiary that is evidence-based. Due to the flexibility being afforded to clinicians to develop an individualized care plan, we encourage Palmetto to educate its medical review staff on this policy and that providers are afforded the ability to use their clinical expertise in crafting a treatment plan tailored to the needs of each beneficiary that is evidence-based. This would help to ensure that medical review decisions are made with consideration of the beneficiary s total condition and individual need for care. APTA also requests that Palmetto describe what it would deem relevant evidence to support the reasonableness of the therapeutic approach being used for a beneficiary. We have concerns that without greater clarification, medical review staff will rely on the imprecise term relevant evidence to issue denial decisions despite the medical necessity of the program. Location of Treatment Pursuant to the NCD, a SET program must be conducted only in a hospital outpatient setting or physician s office. While we appreciate that CMS expanded the setting to include a physician s office, APTA believes the setting restrictions could pose an access barrier, as more patients would benefit if the number of settings where SET can be delivered is expanded. As highlighted above, physical therapists already provide treatment in a number of different settings including private practices, hospitals, SNFs, home health agencies, rehabilitation agencies, and comprehensive outpatient rehabilitation facilities. Expanding the number of permissible settings where SET can be furnished would promote accessibility for beneficiaries in need of physical therapy. A substantial number of beneficiaries seek physical therapy due to issues with pain, mobility, or strength, which makes travel difficult. In fact, this may prompt beneficiaries to seek out SET in the first place. Restricting access to SET to a hospital outpatient setting or physician s office may actually hinder beneficiaries from accessing medically necessary services, due to an inability to reach the appropriate facility. It is imperative that Medicare beneficiaries, both those who reside in metropolitan as well as rural areas, have equitable access to health care services. While rural areas are adopting new ways to provide access to clinical expertise, such as through telehealth, access remains limited. 4
5 We urge Palmetto, and CMS, to consider whether it may be more appropriate to expand the number of settings in which a SET program may be delivered, either in a SNF, assisted living facility, or in the beneficiary s home. Discharge from SET The purpose of a LCD is to help avoid situations in which claims are paid or denied without a provider having a full understanding of the basis for payment and denial. 3 Here, Palmetto states that within the LCD that treatment must continue only as long as benefits, as measured by meaningful reductions in activity limitations exceed risks of treatment. For beneficiaries who are not tolerating treatment or progressing as expected, it is encouraged that they be sent back to the referring provider to develop a new treatment strategy for PAD. While APTA acknowledges that Palmetto has recognized a need to further define NCD 20.35, we have concerns that this proposed discharge policy is subject to provider misinterpretation, which could pose an access issue for beneficiaries and/or result in claim denials due to lack of understanding of the policy. Therefore, we recommend that Palmetto clarify this draft policy to better promote continued access to SET for PAD with symptomatic lower extremity intermittent claudication. Education for Medical Review Staff As discussed above, following publication of the final LCD, APTA strongly recommends that Palmetto implement immediate, ongoing education to its medical review staff to ensure reviewers have an appropriate understanding of the new coverage policy and associated documentation requirements. Specifically, we recommend that Palmetto provide detailed education to staff which clarifies that a SET program for symptomatic PAD is covered when the therapy is appropriate. We have concerns that lack of a proper understanding of the policy by medical reviewers could result in inappropriate denials of SET even when it is clear that the program is appropriate and would benefit the beneficiary. Conclusion We thank Palmetto GBA for the opportunity to comment on the draft LCD, Supervised Exercise Therapy for the Treatment of Peripheral Arterial Disease with Symptomatic Lower Extremity Intermittent Claudication (DL37774). APTA is eager to engage in meaningful dialogue and work with Palmetto in developing a payment model that safeguards Medicare beneficiaries access to medically necessary SET. If you have any questions regarding our comments, please contact Kara Gainer, Director of Regulatory Affairs, at karagainer@apta.org or 703/ Thank you for your consideration. Sincerely, Sharon L. Dunn, PT, PhD Board-Certified Clinical Specialist in Orthopaedic Physical Therapy President 3 Medicare Program Integrity Manual, Chapter 13, Section Guidance/Guidance/Manuals/Downloads/pim83c13.pdf Accessed June 13,
December 18, Submitted Electronically
December 18, 2017 Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-4182-P PO Box 8013 Baltimore, MD 21244-8013 Submitted Electronically
More informationAugust 15, Dear Administrator Verma:
August 15, 2017 Seema Verma, MPH; Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Room 445-G Attn: CMS-1678-P Hubert Humphrey Building 200 Independence
More informationCMS CLARIFICATION JIMMO VS. SEBELIUS
CMS CLARIFICATION JIMMO VS. SEBELIUS Liz Almeida-Sanborn, MS, PT, President Maria Maggi, PT, Vice President of Compliance Jodi Wenzel, MPT, Vice President of Operations OBJECTIVES Participants will: Understand
More informationSeptember 6, Submitted Electronically
September 6, 2013 Ms. Marilyn Tavenner Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1601-P P.O. Box 8013 Baltimore, MD 21244-1850 Submitted
More informationGUIDELINES: PEER REVIEW TRAINING BOD G [Amended BOD ; BOD ; BOD ; Initial BOD ] [Guideline]
GUIDELINES: PEER REVIEW TRAINING BOD G03-05-15-40 [Amended BOD 03-04-17-41; BOD 03-01-14-50; BOD 03-99-15-48; Initial BOD 06-97-03-06] [Guideline] I. Purpose Guidelines: Peer Review Training provide direction
More informationVia Electronic Submission. March 13, 2017
APTQI 20 F Street, NW Suite #700 Washington, DC 20001 Phone: 202-507-6354 www.aptqi.com Via Electronic Submission Centers for Medicare & Medicaid Services Department of Health & Human Services Attention:
More informationPHYSICAL MEDICINE AND REHABILITATION CSHCN SERVICES PROGRAM PROVIDER MANUAL
PHYSICAL MEDICINE AND REHABILITATION CSHCN SERVICES PROGRAM PROVIDER MANUAL NOVEMBER 2017 CSHCN PROVIDER PROCEDURES MANUAL NOVEMBER 2017 PHYSICAL MEDICINE AND REHABILITATION Table of Contents 30.1 Enrollment......................................................................
More informationA A ~l~js AM f'ricj\n ACADBl\IY OF 0RTllOPAEDIC SURGEONS ~ J AMERICAN A SOCIATION OF ORTHOPAEDIC SURGEONS. Therapy billing for beginners
Therapy billing for beginners http://www.aaos.org/news/aaosnow/nov10/managing1.asp 1 of 4 3/25/2014 2:56 PM A A ~l~js AM f'ricj\n ACADBl\IY OF 0RTllOPAEDIC SURGEONS ~ J AMERICAN A SOCIATION OF ORTHOPAEDIC
More informationNo An act relating to health insurance coverage for early childhood developmental disorders, including autism spectrum disorders. (S.
No. 158. An act relating to health insurance coverage for early childhood developmental disorders, including autism spectrum disorders. (S.223) It is hereby enacted by the General Assembly of the State
More informationExpiring Medicare Provider Payment Policies. United States House of Representatives Committee on Ways and Means Subcommittee on Health
Expiring Medicare Provider Payment Policies United States House of Representatives Committee on Ways and Means Subcommittee on Health September 21, 2011 Justin Moore, PT, DPT Vice President, Government
More informationNEW YORK STATE MEDICAID PROGRAM REHABILITATION SERVICES POLICY GUIDELINES
NEW YORK STATE MEDICAID PROGRAM REHABILITATION SERVICES POLICY GUIDELINES Version 2010-1 June 10, 2010 Page 1 of 8 Table of Contents SECTION I REQUIREMENTS FOR PARTICIPATION IN MEDICAID. 3 PROVIDER/QUALIFYING
More informationPhysical therapists also may be certified as clinical specialists through the American Board of Physical Therapy Specialists (ABPTS).
GUIDELINES: PHYSICAL THERAPY CLAIMS REVIEW BOD G08-03-03-07 [Amended BOD 03-03- 13-29; BOD 02-02-22-31; BOD 03-01-16-52; BOD 03-00-22-56; BOD 03-99-16-50; Initial BOD 11-97- 16-54] [Guideline] The American
More information1-Appropriate Use Criteria for Advanced Diagnostic Imaging Services
The Honorable Seema Verma, Administrator Centers for Medicare and Medicaid Services Attention: CMS 1676 P P.O. Box 8016 Baltimore, MD 21244 1850 Dear Administrator Verma: September 10, 2017 On behalf of
More informationTherapy Services INDIANA HEALTH COVERAGE PROGRAMS. Copyright 2017 DXC Technology Company. All rights reserved.
INDIANA HEALTH COVERAGE PROGRAMS PROVIDER REFERENCE M ODULE Therapy Services L I B R A R Y R E F E R E N C E N U M B E R : P R O M O D 0 0 0 4 9 P U B L I S H E D : A U G U S T 1, 2 0 1 7 P O L I C I E
More informationASN respectfully requests that CGS Administrators revise the LCD to:
December 22, 2017 CGS Administrators, LLC Earl Berman, MD Attn Medical Review Two Vantage Way Nashville, TN 37228 Dear Dr. Berman: On behalf of the American Society of Nephrology (ASN), thank you for the
More informationMedicare Physician Fee Schedule Final Rule for CY 2018 Appropriate Use Criteria for Advanced Diagnostic Imaging Services Summary
Medicare Physician Fee Schedule Final Rule for CY 2018 Appropriate Use Criteria for Advanced Diagnostic Imaging Services Summary Background and Overview The Protecting Access to Medicare Act of 2014 included
More informationMedicare Documentation Guidelines For Physical Therapy 2011
Medicare Documentation Guidelines For Physical Therapy 2011 As we move right along with our review of documentation strategies, this week we will for Medicare Part B and for carriers who follow Medicare
More informationJune 9, Michael L. LeFevre, M.D., M.S.P.H. Chair, United States Preventive Services Task Force 540 Gaither Road Rockville, MD 20850
June 9, 2014 Michael L. LeFevre, M.D., M.S.P.H. Chair, United States Preventive Services Task Force 540 Gaither Road Rockville, MD 20850 Re: Draft Recommendation Statement: Behavioral Counseling to Promote
More informationLAWS OF ALASKA AN ACT
LAWS OF ALASKA 01 Source HCS SB (RLS) am H Chapter No. AN ACT Requiring insurance coverage for autism spectrum disorders, describing the method for establishing a covered treatment plan for those disorders,
More informationRe: Orthotics and Prosthetic Services Provided by Occupational Therapists and Physical Therapists under the Medicare Program
July 15, 2010 Peter Budetti, MD, JD Deputy Administrator, Center for Program Integrity Centers for Medicare and Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Mail
More informationTexas Administrative Code
RULE 19.1301 Provision of Rehabilitative Services (a) Provision of services. If rehabilitative services, such as, but not limited to, physical therapy, speech/language pathology, occupational therapy,
More informationNovember 19, Dear Messrs. Holdren and Lander:
John P. Holdren, Co-Chair Eric Lander, Co-Chair President s Council of Advisors on Science and Technology Executive Office of the President 1650 Pennsylvania Avenue, NW Washington, DC 20504 Dear Messrs.
More informationFAQ FOR THE NATA AND APTA JOINT STATEMENT ON COOPERATION: AN INTERPRETATION OF THE STATEMENT September 24, 2009
FAQ FOR THE NATA AND APTA JOINT STATEMENT ON COOPERATION: AN INTERPRETATION OF THE STATEMENT September 24, 2009 Introduction The NATA considers the Joint Statement on Cooperation a very positive resolution
More informationContractor Name: Novitas Solutions, Inc. Contractor Number: Contractor Type: MAC B. LCD ID Number: L34834 Status: A-Approved
LCD for Blood Glucose Monitoring in a Skilled Nursing Facility (SNF) (L34834) Contractor Name: Novitas Solutions, Inc. Contractor Number: 12502 Contractor Type: MAC B LCD ID Number: L34834 Status: A-Approved
More informationAdmission Criteria Continued Stay Criteria Discharge Criteria. All of the following must be met: 1. Member continues to meet all admission criteria
CMS Local Coverage Determination (LCD) of Psychiatry and Psychology Services for Massachusetts, New York, and Rhode Island L33632 Outpatient Services Coverage Indications and Limitations Hospital outpatient
More informationISSUE DATE: 2/10/2006
BULLETIN COMMONWEALTH OF PENNSYLVANIA Department of Public Welfare Department of Health NUMBER: OMHSAS-06-03 ISSUE DATE: 2/10/2006 EFFECTIVE DATE: Immediately SUBJECT: Co-Occurring Disorder Competency
More informationRE: Coverage of low-dose Computed Tomography (LDCT) lung cancer screening in Independent Diagnostic Testing Facilities (IDTFs)
May 11, 2018 Tamara Syrek Jensen, JD Director, Coverage and Analysis Group Department of Health and Human Services Center for Medicare and Medicaid Services 7500 Security Boulevard, Mail Stop S3-02-01
More informationRE: CMS-4130-P (Medicare Program; Policy and Technical Changes to the Medicare Prescription Drug Benefit)
Herb Kuhn, Acting Deputy Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W. Department of Health and Human Services Washington, D.C. 20201
More informationSubmitted to: Re: Comments on CMS Proposals for Patient Condition Groups and Care Episode Groups
April 24, 2017 The Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue SW Washington, D.C. 20201 Submitted to: macra-episode-based-cost-measures-info@acumenllc.com
More informationMedicare Myths-Busters: Dispelling Common Compliance Misconceptions. Learner Objectives. Learner Objectives
Medicare Myths-Busters: Dispelling Common Compliance Misconceptions Rick Gawenda, PT President Gawenda Seminars & Consulting, Inc. September 30, 2017 Learner Objectives Identify the supervision requirements
More informationApril 1, Dear Members of the Pain Management Best Practices Inter-Agency Task Force,
April 1, 2019 U.S. Department of Health and Human Services Office of the Assistant Secretary for Health 200 Independence Avenue, S.W., Room 736E, Attn: Alicia Richmond Scott, Task Force Designated Federal
More informationScope of Practice for the Diagnostic Ultrasound Professional
Scope of Practice for the Diagnostic Ultrasound Professional Copyright 1993-2000 Society of Diagnostic Medical Sonographers, Dallas, Texas USA: All Rights Reserved Worldwide. Organizations which endorse
More informationPulmonary Rehabilitation. Palmetto GBA, Jurisdiction 11 MAC Provider Outreach and Education
Pulmonary Rehabilitation Palmetto GBA, Jurisdiction 11 MAC Provider Outreach and Education Pulmonary Rehabilitation Pulmonary Rehabilitation is a multi-disciplinary program of care for patients with chronic
More informationTaking Part B Therapy Beyond the $3,700 Threshold New Manual Medical Review Process Effective date October 1, 2012
Taking Part B Therapy Beyond the $3,700 Threshold New Manual Medical Review Process Effective date October 1, 2012 Presented by: Leigh Ann Frick, PT, MBA Vice President of Clinical Services Heritage Healthcare
More information(A) results from that individual's participation in or training for sports, fitness training, or other athletic competition; or
VT AT Act 12/04 Title 26: Professions and Occupations Chapter 83: ATHLETIC TRAINERS 4151. Definitions As used in this chapter: (1) "Athlete" means any individual participating in fitness training and conditioning,
More informationUS H.R.6 of the 115 th Congress of the United States Session
US H.R.6 of the 115 th Congress of the United States 2017-2018 Session This Act may be cited as the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities
More informationThe AAO- HNS s position statement on Point- of- Care Imaging in Otolaryngology states that the AAO- HNS,
AAO- HNS Statement on Diagnostic Imaging Reimbursement for Otolaryngologist Head and Neck Surgeons (September 2014) The American Academy of Otolaryngology Head and Neck Surgery (AAO- HNS), with approximately
More informationMedicare Benefit Policy Manual
Medicare Benefit Policy Manual Chapter 15 Covered Medical and Other Health Services Table of Contents (Rev. 222, 05-13-16) Transmittals for Chapter 15 10 - Supplementary Medical Insurance (SMI) Provisions
More informationOCTOBER EOEA and the Alzheimer s Association have organized implementation of the plan around its five major recommendations:
1 MASSACHUSETTS ALZHEIMER S DISEASE AND RELATED DISORDERS STATE PLAN RECOMMENDATIONS TWO-YEAR PROGRESS REPORT OCTOBER 2014 In February 2012, Massachusetts released a set of Alzheimer s Disease and Related
More informationClaim Submission. Agenda 1/31/2013. Payment Basics
February 2013 Jean C. Russell, MS, RHIT jrussell@epochhealth.com Richard Cooley, BA, CCS rcooley@epochhealth.com 518-430-1144 2 Payment Basics Agenda 2013 PT / OT / SP Codes Deleted Codes New Codes Significant
More informationAvailable at: Bioethics.gov
For Researchers: Neuroscience and Consent Capacity In March 2015, the Presidential Commission for the Study of Bioethical Issues (Bioethics Commission) released its report, Gray Matters: Topics at the
More informationDental Therapy Toolkit SUMMARY OF DENTAL THERAPY REGULATORY AND PAYMENT PROCESSES
Dental Therapy Toolkit SUMMARY OF DENTAL THERAPY REGULATORY AND PAYMENT PROCESSES March, 2016 OFFICE OF RURAL HEALTH AND PRIMARY CARE EMERGING PROFESSIONS PROGRAM Acknowledgements This report was developed
More informationKANSAS MEDICAL ASSISTANCE PROGRAM. Fee-for-Service Provider Manual. Rehabilitative Therapy Services
Fee-for-Service Provider Manual Rehabilitative Therapy Services Updated 12.2015 PART II (PHYSICAL THERAPY, OCCUPATIONAL THERAPY, SPEECH/LANGUAGE PATHOLOGY) Introduction Section BILLING INSTRUCTIONS Page
More informationFor An Act To Be Entitled. Subtitle
0 0 State of Arkansas INTERIM STUDY PROPOSAL 0-0th General Assembly A Bill DRAFT JMB/JMB Second Extraordinary Session, 0 SENATE BILL By: Senator J. Hutchinson Filed with: Arkansas Legislative Council pursuant
More informationOFFICE OF MENTAL HEALTH AND SUBSTANCE ABUSE SERVICES BULLETIN
OFFICE OF MENTAL HEALTH AND SUBSTANCE ABUSE SERVICES BULLETIN ISSUE DATE January 13, 2017 EFFECTIVE DATE: Immediately NUMBER: OMHSAS-17-02 SUBJECT: BY: Applied Behavioral Analysis Using Behavioral Specialist
More informationLocal Coverage Determination (LCD) for Chiropractic Services (L34816) (Posted for Notice)
Local Coverage Determination (LCD) for Chiropractic Services (L34816) (Posted for Notice) Print Contractor Information Contractor Name Novitas Solutions, Inc. Contractor Numbers 04911, 07101, 07102, 07201,
More informationCHAPTER Section 3 of P.L.1983, c.296 (C.45: ) is amended to read as follows:
CHAPTER 121 AN ACT concerning the practice of physical therapy, amending P.L.2003, c.18, and amending and supplementing P.L.1983, c.296. BE IT ENACTED by the Senate and General Assembly of the State of
More informationTitle 32: PROFESSIONS AND OCCUPATIONS
Title 32: PROFESSIONS AND OCCUPATIONS Chapter 45-A: PHYSICAL THERAPIST PRACTICE ACT Table of Contents Section 3111. DEFINITIONS... 3 Section 3111-A. SCOPE OF PRACTICE... 3 Section 3112. BOARD CREATED;
More informationRE: Revision of the NSW Health Policy Directive Consent to Medical Treatment Patient Information
Leanne O Shannessy Director, Legal & Regulatory Services Legal & Legislative Services Branch NSW Ministry of Health Locked Bag 691 North Sydney 2059 12 December 2014 Via email: legalmail@doh.health.nsw.gov.au
More informationAdvancing the STOP Stroke Act in the 108 th Congress
Advancing the STOP Stroke Act in the 108 th Congress January 24, 2003 Core Principles The was asked to identify key priorities for legislation to improve the quality of stroke care. The legislation will
More informationJuly 25, Submitted Electronically
July 25, 2014 Submitted Electronically Ms. Marilyn Tavenner Acting Administrator Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services Room445-G, Hubert Humphrey Building
More informationIC ARTICLE MARRIAGE AND FAMILY THERAPISTS
IC 25-23.6 ARTICLE 23.6. MARRIAGE AND FAMILY THERAPISTS IC 25-23.6-1 Chapter 1. Definitions IC 25-23.6-1-1 Application of definitions Sec. 1. The definitions in this chapter apply throughout this article.
More informationHouse Committee on Energy and Commerce House Committee on Energy and Commerce. Washington, DC Washington, DC 20515
February 28, 2018 The Honorable Michael Burgess, M.D. The Honorable Gene Green Chairman Ranking Member Subcommittee on Health Subcommittee on Health House Committee on Energy and Commerce House Committee
More informationVia Electronic Submission. September 10, 2018
APTQI 20 F Street, NW Suite #700 Washington, DC 20001 Phone: 202-507-6354 www.aptqi.com Via Electronic Submission The Honorable Seema Verma, Administrator Centers for Medicare & Medicaid Services Department
More informationChapter 18 Section 2. EXPIRED - Department Of Defense (DoD) Cancer Prevention And Treatment Clinical Trials Demonstration
s And Pilot Projects Chapter 18 Section 2 EXPIRED - Department Of Defense (DoD) Cancer Prevention And Treatment Clinical Trials 1.0 PURPOSE The purpose of this demonstration is to improve TRICARE-eligible
More informationProfessional CGM Reimbursement Guide
Professional CGM Reimbursement Guide 2015 TABLE OF CONTENTS Coding, Coverage and Payment...2 Coding and Billing...2 CPT Code 95250...3 CPT Code 95251...3 Incident to Billing for Physicians..............................................
More informationAuthorized By: Elizabeth Connolly, Acting Commissioner, Department of Human
HUMAN SERVICES 48 NJR 7(2) July 18, 2016 BUREAU OF GUARDIANSHIP SERVICES Decision-Making for the Terminally Ill Proposed Readoption with Amendments: N.J.A.C. 10:48B Authorized By: Elizabeth Connolly, Acting
More informationFederation of State Boards of Physical Therapy
Federation of State Boards of Physical Therapy Mission: public protection Leslie Adrian, PT, DPT, MS, MPA Director of Professional Standards Physical Therapy Licensure Compact Improving the way we protect
More informationFacilitate physician access to compounded drugs for office-use from 503A compounding pharmacies for patients with emergent conditions;
By Electronic Delivery Scott Gottlieb, MD Commissioner Food and Drug Administration Attn: Division of Dockets Management (HFA-305) 5630 Fishers Lane, Rm. 1061 Rockville, MD 20852 Re: FDA-2017-N-5093 for
More informationJurisdiction New Mexico. Retirement Date N/A
Local Coverage Determination (LCD): Chiropractic Services (L34816) Contractor Information Contractor Name Novitas Solutions, Inc. opens in new Contract Number 04212 Contract Type A and B MAC J - H LCD
More information31 October Professor Bruce Robinson Chair, Medicare Benefits Schedule Review Taskforce Department of Health
31 October 2018 Professor Bruce Robinson Chair, Medicare Benefits Schedule Review Taskforce Department of Health By email to: mbsreviews@health.gov.au Dear Professor Robinson Re: Report from the Eating
More informationSubmitted online at
May 26, 2015 Regulatory Analysis and Development Program Planning and Development Animal and Plant Health Inspection Service (APHIS) U.S. Department of Agriculture (USDA) Station 3A-03.8 4700 River Road
More informationALLIANCE OF WOUND CARE STAKEHOLDERS. Palmetto GBA Public Meeting Draft LCD on Application of Skin Substitutes (DL36466) October 13, 2015
ALLIANCE OF WOUND CARE STAKEHOLDERS Palmetto GBA Public Meeting Draft LCD on Application of Skin Substitutes (DL36466) October 13, 2015 1 ALLIANCE OF WOUND CARE Who is the Alliance? STAKEHOLDERS A non-profit
More information750 First Street, N.E. Washington, DC (202) (202) Fax (202) TDD
September 10, 2018 Seema Verma Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8016 Baltimore, Maryland 21244-8016. Re: CMS-1693-P Medicare Program;
More informationGUIDELINES: CLINICAL INSTRUCTORS BOD G [Amended BOD G ; BOD ; BOD ; Initial BOD ] [Guideline]
GUIDELINES: CLINICAL INSTRUCTORS BOD G03-06-21-55 [Amended BOD G03-04-22-56; BOD 11-01-06-09; BOD 03-99-23-75; Initial BOD 11-92-43-201] [Guideline] Preamble Clinical education represents a significant
More informationCase Review of Inpatient Rehabilitation Hospital Patients Not Suited for Intensive Therapy
U.S. DEPARTMENT OF HEALTH & HUMAN SERVICES OFFICE OF INSPECTOR GENERAL Case Review of Inpatient Rehabilitation Hospital Patients Not Suited for Intensive Therapy OEI-06-16-00360 DECEMBER 2016 SUZANNE MURRIN
More informationCounseling to Prevent Tobacco Use
News Flash Vaccination is the Best Protection Against the Flu. This year, the Centers for Disease Control and Prevention (CDC) is encouraging everyone 6 months of age and older to get vaccinated against
More information[CORRECTED COPY] CHAPTER 115
[CORRECTED COPY] CHAPTER 115 AN ACT concerning the practice of optometry and revising parts of the statutory law. BE IT ENACTED by the Senate and General Assembly of the State of New Jersey: 1. R.S.45:12-1
More informationAttn: Alicia Richmond Scott, Pain Management Task Force Designated Federal Officer
March 18, 2019 Office of the Assistant Secretary of Health U.S. Department of Health and Human Services 200 Independence Avenue SW, Room 736E Washington, DC 20201 Attn: Alicia Richmond Scott, Pain Management
More information16 SB 319/AP. Senate Bill 319 By: Senators Jackson of the 2nd, Kirk of the 13th, Unterman of the 45th, Henson of the 41st and Orrock of the 36 th
1 2 3 4 5 6 7 8 9 10 11 12 13 Senate Bill 319 By: Senators Jackson of the 2nd, Kirk of the 13th, Unterman of the 45th, Henson of the 41st and Orrock of the 36 th AS PASSED A BILL TO BE ENTITLED AN ACT
More informationFSBPT Supervised Clinical Practice Performance Evaluation Tool
1. Practices in a manner that is safe for the patient 1.1. Responds appropriately in emergency situations 1.2. Recognizes and responds to unexpected changes in patient's physiological condition 1.3. Utilizes
More informationRE: Proposed National Coverage Decision (NCD) Memorandum for Percutaneous Left Atrial Appendage Closure (LAAC) Therapy (CAG-00445N)
December 10, 2015 Ms. Tamara Syrek-Jensen Director, Coverage & Analysis Group Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 RE: Proposed National Coverage Decision
More informationWhat am I Looking For?: A Reviewer s Guide to Therapy Documentation
What am I Looking For?: A Reviewer s Guide to Therapy Documentation Presented By: Cindy Krafft MS PT, COS-C Director of Rehabilitation Consulting Services President - Home Health Section APTA November
More informationLicensure Portability Resource Guide FSBPT. Ethics & Legislation Committee Foreign Educated Standards 12/17/2015
2015 Licensure Portability Resource Guide FSBPT Ethics & Legislation Committee Foreign Educated Standards 12/17/2015 Licensure Portability Resource Guide Introduction In the current health care environment,
More informationSENATE, No STATE OF NEW JERSEY. 217th LEGISLATURE INTRODUCED FEBRUARY 8, 2016
SENATE, No. STATE OF NEW JERSEY th LEGISLATURE INTRODUCED FEBRUARY, 0 Sponsored by: Senator JOSEPH F. VITALE District (Middlesex) SYNOPSIS Makes it a crime of the third degree to practice psychology without
More informationStrengthening the post-stroke psychological care pathway: Examples from four North-West of England sites
Strengthening the post-stroke psychological care pathway: Examples from four North-West of England sites Background Range of psychological problems post-stroke Common and disabling Impacts on rehabilitation
More informationOral Appliances for Obstructive Sleep Apnea Response to Comments
Oral Appliances for Obstructive Sleep Apnea Response to Comments November 11, 2010 1. There are no randomized, controlled crossover trials that show efficacy of any prefabricated oral appliance. As the
More informationAlabama Rural Hospital Flexibility Program. Application Instructions for Supplement A - Conversion to a Critical Access Hospital
Alabama Rural Hospital Flexibility Program Application Instructions for Supplement A - Conversion to a Critical Access Hospital Introduction Alabama hospitals that wish to convert to Critical Access Hospital
More informationSTATE OF MINNESOTA BOARD OF DENTISTRY GENERAL STATEMENT
This document is made available electronically by the Minnesota Legislative Reference Library as part of an ongoing digital archiving project. http://www.leg.state.mn.us/lrl/sonar/sonar.asp STATE OF MINNESOTA
More informationHIGHLIGHTS OF THE 2017 PROPOSED MEDICARE PHYSICIAN FEE SCHEDULE RULE
HIGHLIGHTS OF THE 2017 PROPOSED MEDICARE PHYSICIAN FEE SCHEDULE RULE July 13, 2016 INTRODUCTION The Medicare Physician Fee Schedule proposed rule released by the Centers for Medicare and Medicaid Services
More informationPositive Airway Pressure (PAP) Devices Physician Frequently Asked Questions December 2008
Positive Airway Pressure (PAP) Devices Physician Frequently Asked Questions December 2008 Based on questions received from the clinical community, the following Frequently Asked Questions will address
More informationDear Dr. Kloiber, Our comments on paragraphs 15, 22, and 34 of the April 2013 draft proposal follow. Sincerely,
June 15, 2013 Dr. Otmar Kloiber Secretary General of the World Medical Association By email to: doh@wma.net 13, ch. du Levant CIB - Bâtiment A 01210 Ferney-Voltaire France Dear Dr. Kloiber, Please accept
More informationInclude Substance Use Disorder Services in New Hampshire Medicaid Managed Care
Include Substance Use Disorder Services in New Hampshire Medicaid Managed Care New Futures mission is to advocate, educate, and collaborate to reduce alcohol and other drug problems in New Hampshire. Expanding
More information104 CMR: DEPARTMENT OF MENTAL HEALTH 104 CMR 33.00: DESIGNATION AND APPOINTMENT OF QUALIFIED MENTAL HEALTH PROFESSIONALS
104 CMR 33.00: DESIGNATION AND APPOINTMENT OF QUALIFIED MENTAL HEALTH PROFESSIONALS Section 33.01: Legal Authority to Issue 33.02: Authorization to Apply for Hospitalization Pursuant to M.G.L. c. 123,
More informationENABLING RECOVERY FROM COMMON TRAFFIC INJURIES: A FOCUS ON THE INJURED PERSON Response of the Ontario Physiotherapy Association
ENABLING RECOVERY FROM COMMON TRAFFIC INJURIES: A FOCUS ON THE INJURED PERSON Response of the Ontario Physiotherapy Association INTRODUCTION The Ontario Physiotherapy Association (OPA), a branch of the
More informationSummary of House of Delegates Activities American Physical Therapy Association (APTA) House of Delegates June 2013
Summary of House of Delegates Activities American Physical Therapy Association (APTA) House of Delegates June 2013 [NOTE; A POST-HOUSE PACKET CONTAINING THE FULL MOTION LANGUAGE IS AVAILABLE AT THE HOUSE
More informationMedicare Physical Therapy Billing Guidelines 2012
Medicare Physical Therapy Billing Guidelines 2012 Important Notice! A random sample of APTA members will soon be selected to respond to a survey about new physical therapy evaluation and reevaluation CPT.
More informationDraft Regulation R-013: Spousal Exemption to Sexual Abuse Provisions and Draft Standard of Practice S-032: Providing Chiropractic Care to a Spouse
ONTARIO CHIROPRACTIC ASSOCIATION ASSOCIATION CHIROPRATIQUE DE L ONTARIO March 26, 2015 Joel Friedman, Director, Policy and Research College of Chiropractors of Ontario 130 Bloor St. West, Suite 902 Toronto,
More informationSubmitted to the House Energy and Commerce Committee. Federal Efforts to Combat the Opioid Crisis
STATEMENT FOR THE RECORD Submitted to the House Energy and Commerce Committee Federal Efforts to Combat the Opioid Crisis October 25, 2017 America s Health Insurance Plans 601 Pennsylvania Avenue, NW Suite
More informationStudents With Attention Deficit Hyperactivity Disorder
On January 29, 2018 the Arizona State Board of Education approved a list of qualified professionals for identification of educational disabilities as developed by the Arizona Department of Education. Categories
More informationSTATE OPERATIONS MANUAL
STATE OPERATIONS MANUAL Appendix W Survey Protocol, Regulations and Interpretive Guidelines for Critical Access Hospitals (CAHs) And Swing-Beds in CAHs Revisions 84, 06-07-21013 C-0151 Physician Ownership
More informationAct 443 of 2009 House Bill 1379
Act 443 of 2009 House Bill 1379 AN ACT TO PROVIDE FOR THE LICENSURE OF ALCOHOLISM AND DRUG ABUSE COUNSELORS; TO PROVIDE FOR THE REGISTRATION OF CLINICAL ALCOHOLISM AND DRUG ABUSE COUNSELOR SUPERVISORS;
More informationThe Vision. The Objectives
The Vision Older people participate to their fullest ability in decisions about their health and wellbeing and in family, whānau and community life. They are supported in this by co-ordinated and responsive
More informationMary Ann Hodorowicz RDN, MBA, CDE, CEC (Certified
Mary Ann Hodorowicz RDN, MBA, CDE, CEC (Certified Endocrinology Coder) Mary Ann Hodorowicz, RDN, MBA, CDE, CEC, is a licensed registered dietitian and certified diabetes educator and earned her MBA with
More informationFebruary 13, The Honorable Fred Upton 2183 Rayburn House Office Building Washington, DC Dear Chairman Upton:
NATIONAL OFFICE Advocacy and Access Department 1615 L Street, NW #320 Washington, DC 20036 February 13, 2015 The Honorable Fred Upton 2183 Rayburn House Office Building Washington, DC 20515 Dear Chairman
More informationUnderstanding Hierarchical Condition Categories (HCC)
Understanding Hierarchical Condition Categories (HCC) How hierarchical condition category coding will impact your practice and how you can use these codes to increase quality, improve the patient experience,
More informationAPTA EDUCATION STRATEGIC PLAN ( ) BOD Preamble
APTA EDUCATION STRATEGIC PLAN (2006-2020) BOD 03-06-26-67 Preamble The content of the Education Strategic Plan represents the specific initiatives the American Physical Therapy Association (Association)
More informationClinical Teaching While Sustaining or Improving Productivity:
Clinical Teaching While Sustaining or Improving Productivity: How to Manage or Maximize Productivity with Students Kurt Neelly, PT PhD Associate Professor Director of Clinical Education Western Kentucky
More informationNew Department of Education Guidance Issued to Ensure Access to Speech-Language Pathology Services for Children With Autism
CONTACT Joseph Cerquone 301-296-8732 jcerquone@asha.org New Department of Education Guidance Issued to Ensure Access to Speech-Language Pathology Services for Children With Autism ASHA Advocated Strongly
More information