Last chance to stave off a penalty reduction in reimbursement.
By Nancy J. Beckley, MS, MBA, CHC
This compliance topic is in response to requests by many private practice members to understand the Physician Quality Reporting System (PQRS) and to effectively report to stave off future payment reductions. The focus is on claims-based reporting. American Physical Therapy Association (APTA) members are encouraged to visit www.apta.org/PQRS for a wealth of information about the PQRS program including reporting requirements.
Q: My Medicare reimbursement this year is being reduced for each code that I bill. When I called my Medicare Administrative Contractor to inquire about this reduction, I was told that it was related to nonparticipation in the PQRS program in 2013. Is there any way that I can stop this payment cut?
A: Late in 2014, the Centers for Medicare & Medicaid Services (CMS) Center for Clinical Standards and Quality sent letters to eligible professionals who did not participate in the 2013 PQRS program indicating the criteria to avoid the 2015 PQRS payment adjustment. The letter further explained: “CMS will reduce all Medicare Physician Fee Schedule (MPFS) payments for services rendered January 1, 2015 through December 31, 2015 and billed using this Tax Identification Number/National Provider Identifier (TIN/NPI) combination by 1.5 percent.”
CMS alerted providers to the reality of payment reductions for nonperformance throughout 2013 and, in fact, implemented a provision that if one code for one patient was successfully reported a provider could stave off the 2013 1.5 percent reduction to Medicare reimbursements.
Q: Is participation in PQRS voluntary? If it is voluntary why is there a penalty for not participating? Can you clarify the rules regarding participation?
A: Participation is voluntary; however, the penalties are now in effect and are increasing. Some providers elected, for a variety of reasons, to not participate in 2013 and 2014, weighing the loss of Medicare reimbursement against the cost of participation. The 1.5 percent payment reduction this year is based on 2013 performance. Providers not participating, or not successfully participating, in 2014 will receive a 2 percent payment reduction in 2016. If an eligible provider does not successfully participate in 2015, a 2 percent payment reduction will be applied in 2017. During the early years of PQRS (originally called Physician Quality Reporting Initiative [PQRI]), a bonus was offered for those who successfully participated.
Q: Is there still time to participate in PQRS in 2015 and if so how does a private practice get started?
A: There is a last chance opportunity to begin participation in PQRS this year in order to prevent the 2 percent penalty in 2017. Time is short and participation will need to be monitored closely for accuracy. Each individual provider will need to report all 6 claims measures on 50 percent or more of all of eligible Medicare patients for the 2015 calendar year. Given a late start it is likely that measures will need to be reported for 100 percent of Medicare patients. The APTA has resources to assist a provider new to PQRS at www.apta.org/PQRS.
Providers can start by using claims-based reporting, which is free. There is also an option to report via registry. Several therapy-based registries exist, including those that are associated with specific electronic medical record (EMR) programs. The 2015 listing of registries through which therapy providers may report can be found at: www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2015_Qualified_Registries.pdf.
Q: What are the reporting requirements for PQRS claims-based reporting?
A: Measures required for physical therapy claims-based reporting in 2015 are noted in the table below. Additionally APTA has provided content on both claims-based reporting and registry reporting that should be used as a guide when initiating PQRS reporting to ensure compliance. APTA also provides helpful data collection sheets for each measure.
Q: If a clinic is getting a late start to PQRS, how can they ensure that they are meeting the reporting requirements?
A: Providers should visit the QualityNet website to register for an account. QualityNet also provides a Help Desk for providers. QualityNet can be accessed at: www.qualitynet.org/portal/server.pt/community/pqri_home/212.
Q: I plan to leave my current private practice at the end of June and in this practice we are not participating in PQRS. I am going to another private practice in the same town that does participate in PQRS, and they are concerned because I did not previously participate that I might affect their results and ultimately their reimbursement. My new practice wants to ensure that they do not receive a payment reduction for my therapy billings.
A: There is good news for your new practice. Participation in PQRS is tied to both the individual provider (physical therapist) number and the practice TIN. So your participation at your previous practice linked your NPI number with that practice’s TIN. When you move to your new practice your participation will be measured for that practice, and will not take into consideration participation (or nonparticipation) with your previous practice.
Q: Can you explain the difference between PQRS and functional limitation reporting (FLR)? Are they using the same G codes?
A: The PQRS program as well as functional limitation reporting both use “G codes,” which often is the source of confusion among providers. (Not all PQRS reporting is represented with a “G code,” but all functional limitation category selections for current function, goal function, and discharge function are “G codes”). PQRS Quality Data Codes (QDCs) coding is unique to each measure and the measure specifications for use of the codes is contained in each measure’s description.
Functional limitation reporting, often referred to as claims-based outcome reporting, is required for all providers billing the Medicare Part B program for therapy services. Only providers enrolled in Medicare as a “supplier,” such as a physical therapist in private practice, can participate in the PQRS program at this time in large part due to the ability to report based on individual therapist NPI numbers. Therapists working in hospitals, skilled facilities, rehab agencies, Comprehensive Outpatient Rehabilitation Facilities (CORFs), and home health agencies do not bill under their provider number, but rather the facility number and bill using the UB04 claim form. Private practices (a Medicare “supplier”) bill using their own provider number even if benefits have been assigned to a group practice on the CMS 1500 claim form.
Nancy J. Beckley, MS, MBA, CHC, is certified in health care compliance by the Compliance Certification Board and is a frequent speaker and author on outpatient therapy compliance topics. She advises practices on compliance plan development and audit response. Questions and comments can be directed to firstname.lastname@example.org.
Make consistency a habit.
By Don Levine, PT, DPT, FAFS
As practitioners, owners, and managers, we all understand that honing our skills makes us better able to assist our patients toward their desired outcomes. So, how does that apply to our efforts toward marketing and public relations (PR)? It is exactly the same. Practice makes perfect!
Flex Your Muscles
As Kimberly McCall points out in her article in Inc. Magazine, marketing is a lot like exercise, and consistency is the key.1 How often do we tell our patients, it is vital that they perform their home exercise program regularly to improve. That same concept holds true with regard to implementing a successful marketing or PR program. Hit or miss programs will not provide positive outcomes. Steady, consistent messaging is required to stir your market to action.
Several other marketing experts utilize the analogy of exercise in their discussion of developing effective campaigns. Don Beehler, a PR consultant in Nashville, states, “A start and stop PR effort is a little bit like start and stop exercise—it’s better than none at all, but not nearly as effective as a consistent effort.”2 He goes on to point out that without consistency, top of mind awareness can diminish over time. Much like our patients who, once better, stop doing the things that might keep them healthy, they fail just as we would with our occasional marketing and PR endeavors. Regular marketing and PR, just like regular exercise, is crucial to success.
Stick to It!
Brand consistency is another integral component required for reaching your marketing and PR goals. In her blog,
“3 Reasons Why Brand Consistency Is Important,” Ally Scott points out that many business owners are too relaxed with their messaging efforts and notes that consistency:
- Differentiates you from competitors,
- Increases customer recognition, and
- Reinforces your identity.3
Regular use of your logo and your mission statement—even your colors and your font—will help increase awareness of your practice.
Flexibility, strengthening, proprioception, balance, endurance…
There are many components to a treatment plan just as there are to a successful marketing or PR campaign. In designing a plan for a patient, a physical therapist assists in developing goals and, with those in mind, implements a treatment plan to reach those objectives. While the patient may need work in many different areas, the treatment techniques are consistent with the overall functional aims. In this same light, our marketing and PR plans should resonate with consistency. A campaign will have many avenues to reach current and potential clients: websites, social media, e-newsletters, direct mail, print advertising, etc., and the message needs to be consistent across all elements.
To be effective physical therapists, we must develop a sense of trust with our patients. Successful marketing and PR campaigns require the establishment of trust and credibility with your target market. Eric Holtzclaw outlines the five rules on power of consistency in business, stating that consistency:
- Allows for measurement,
- Creates accountability,
- Establishes your reputation,
- Makes you relevant, and
- Maintains your message.4
Do not confuse and lose your potential clients with inconsistent messaging and branding.
With all of the areas of your practice calling for your attention, it is easy to let your marketing and PR plan take a backseat. Just like a successful exercise program, your marketing and PR campaigns must be well planned and regularly followed to provide the desired outcomes of increasing consumer awareness and driving business through your doors.
Be reputable. Be relevant. Be consistent.
1. Website: www.inc.com/articles/2000/03/17909.html. Accessed May 2015.
2. Website: http://donbeehler.com/tag/pr-consistency. Accessed May 2015.
3. Website: www.pulsemarketingagency.com/Branding/3-reasons-why-brand-consistency-is-important. Accessed May 2015.
4. Website: www.inc.com/eric-v-holtzclaw/consistency-power-success-rules.html. Accessed May 2015.
Don Levine, PT, DPT, FAFS, is chair of the marketing and PR committee and co-owner of Olympic Physical Therapy with five locations in Rhode Island. He can be reached at email@example.com.
By Lee G. Bolman and Terrence E. Deal | Reviewed by Kelly Sanders, PT, DPT, OCS, ATC
How Great Leaders Think: the Art of Reframing by Lee G. Bolman and Terrence E. Deal gives the reader a glimpse of how strong leaders think by revisiting the four-frame model of leadership and organization that they first outlined in their work, Reframing Organizations: Artistry, Choice, and Leadership. This new book provides a shorter, more tangible version of their first work, providing the reader with multiple real-world case reports of leadership.
The book conveys three key messages:
- Good thinking is the starting point for good leadership.
- Leaders who can reframe—look at the same things from multiple perspectives—think better. They create a lucid portrait of what is going on around them and have a clear vision of what is needed to achieve desired results.
- Leaders can see and do more when they know how to negotiate four key areas of the leadership terrain: structural, human resource, political, and symbolic.
One of the things I liked most about this book was that while it went over some theories of management and leadership, the majority of the book focuses on the practical applications of the four frames noted above.
The authors use many case studies of well-known leaders such as Jeff Bezos at Amazon, Tony Hseih at Zappos, and Ursula Burns at Xerox to demonstrate the application of the four frames and outline both good and bad decisions and the impact those had on leaders and companies we all know and follow.
Through these case studies, the authors unravel complex situations and bring clarity to help interpret business situations and make sound decisions. The book also provides tools and leadership strategies to help organize a motivated, high-functioning team of individuals.
Kelly Sanders, PT, DPT, OCS, ATC, is a member of the Impact editorial board and is president of Team Movement for Life, a 19-location outpatient physical therapy practice operating in California and Arizona. Kelly can be reached at firstname.lastname@example.org.
By Terry C. Brown, PT, DPT
It is the weekend after returning home from the American Physical Therapy Association (APTA) NEXT conference and the House of Delegates (HOD); I have mixed emotions as to what occurred. I am a veteran of the HOD after spending 13 years as a Kentucky delegate and six years as the Private Practice Section alternate delegate. I realize this may seem paramount to a prison sentence to some of you, but I have always found it to be a fascinating process that can elicit some profound discussion, or it can be an exercise in futility. This year’s HOD was a bit of both.
Looking at it from my water bottle being half full, let’s start with the positive.
- An excellent discussion regarding the physical therapist’s role in prevention, wellness, fitness, health promotion, and management of disease and disability will help place the profession in its rightful place at the forefront of this important movement.
- A most substantive discussion was had on the feasibility of obtaining primary care practitioner status. The pros and cons of this status were discussed openly and debated with intelligence. Issues regarding ordering imaging and prescribing meds were argued in ways so that I found myself being swayed in both directions. In the end, the decision was made that we are indeed an integral part of the primary care team and the experts in movement disorders, and this is where our efforts should focus.
- Good discussion also occurred on the use of health information technology and electronic medical records, which will help move APTA forward in this important area.
These types of rich debates are what make the HOD a necessary and effective body for our profession.
Now, for the other side, with my water bottle “half empty,” I bemoan the things that we as the governing body of this profession cannot seem to get over. Again, we spent an entire morning discussing the vote, or no vote, or half a vote on the physical therapist assistant (PTA): if the PTA should or should not be a chapter delegate and if the PTA should be able to be elected to the APTA board of directors. Let me preface this report by saying that I have nothing against PTAs and employ two highly qualified and stellar PTAs who enhance our practice. This is more about who sets the professional standards and directs the future rules and regulations of our profession. This act should always remain in the hands of the physical therapist. However, we as the HOD cannot say enough, or discuss enough, or rehash enough, as this subject has come back every year for the majority of my 19 HOD years.
Finally, the HOD voted to continue to not allow the section’s delegates a vote. While we have a voice in the HOD by the right to submit a Reference Committee (RC) and to speak in debates of all RC, we are not given a vote in either the House itself or in the election of APTA leaders. The HOD soundly defeated an RC submitted by the Health Policy and Administration (HPA) section—the catalyst supported by all sections.
So there you have it, my bird’s-eye view from the back of the room on the 2015 House of Delegates.
By Tannus Quatre, PT, MBA
Often times we guess at what people want from us. Whether it be the best, a doctor, or a specialist in XYZ, whatever it is they want, we will so often go to any length to make sure we are that very thing—but what if we are wrong?
What if they do not want the best? Or more likely, what if they assume that is what they are getting every time they see a physical therapist anyway? What if they do not want a doctor, because their physician could not fix them to begin with? What if they do not want a specialist? What if they just want to move better?
Well, if that is what we think they want—and they really do not—then we have not only wasted our time, but we have missed an opportunity. The more we can deliver what our clients actually want from us, the more value we will produce and the richer our profession will become.
And our clients just want more of themselves.
Think about it. Do you buy whitening toothpaste because whiter teeth make your food taste better? Is it because the ingredients are safer or more effective? No. You buy whitening toothpaste because you feel like whiter teeth will make you more attractive or beautiful. The toothpaste helps you be that more ideal version of yourself.
Would you buy a sports car because you want to quickly race to work in the morning? Is it so you can outrun criminals or jump over gulches when the bridge is out? No. You buy a sports car because it makes you feel sporty. In this case, sporty would be closer to that more ideal version of yourself.
So, why does someone come to physical therapy? Is it because their physical therapist has an alphabet soup of credentials behind their name? Is it because their physical therapist has 25 years of experience? No. Someone comes to physical therapy because they want to be the more ideal version of themselves. The version that moves better, has less pain, and can do more things.
By focusing always on them and what we can do to help them get there, we remove a laundry list of distracting elements that get in the way of a very simple truth—that people care about themselves.
So let us be sure they know we can take them there.
Tannus Quatre, PT, MBA, lives at the intersection of physical therapy and entrepreneurship, spending his time helping physical therapists build and operate successful practices through his company, Vantage Clinical Solutions. He specializes in marketing, finance, and business planning, and authors and speaks regularly for the APTA and PPS. He can be reached at email@example.com.