On November 1, CMS published what is popularly known as “The Final Rule” for 2019. The rule book this year is 2,378 pages, most of which do not apply to PT, OT and Speech. For the most part,  it is full of bureaucratic double-speak, references to regulations, history on changes and proposed changes, comments on those changes, and polite refusals to requests for rule changes made by providers and professional organizations. However, there are some nuggets in “The Final Rule” that impact therapists and are vital for therapists to know.

Luckily, we have spent the last two years anticipating these important changes – and the good news is we got most of it right.  Here is a bit of a rundown:

Nailed It!

Merit-Based Incentive Payment System

For the first time, PTs and OTs providing services under the Medicare Professional Fee Schedule are eligible to participate in MIPS. We feel very good about our support for MIPS, utilizing Keet Health and Intermountain ROMS Quality Clinical Data Registry (QCDR) and outcomes analysis system, collectively called Keet Outcomes. Missed our announcement on Keet Outcomes and our MIPS Guarantee? Check it out here.

Our system is designed to help support successful participation in MIPS with an efficient clinical workflow, patient convenience and clinical utility. I could not be prouder of the diligent work done by the teams at Clinicient and Keet in this effort, and I am very proud of our partnership with the team at Intermountain ROMS. Remember, the only way to get any increase in your Medicare Fee Schedule from here on out is to successfully participate in MIPS. This is the most profound change in the transition from fee-for-service to value-based care made by CMS yet. Looking for more resources on this transition? We have tons of additional information in our MIPS Resource Center.

Something we did not anticipate, however, is the inclusion of Speech Language Pathologists as MIPS eligible providers in the final rule. When we read the tea leaves in the proposed rule back in July, it did not appear that SLPs would be included.

Functional Limitation Reporting

It is really going to be gone, effective January 2019. I’m stifling the urge to celebrate the end of this ill-conceived program. In the meantime, continue putting meaningless “G Codes” and “Impairment Modifiers” on your claims. CMS has no plans to make the FLR data public. Good riddance.

The Cap is Gone, but Not Really

You still need to track Medicare Allowed charges for all of your Medicare patients for PT and Speech and track OT charges separately, and stipulate medical necessity at an arbitrary level. The arbitrary level for applying the KX in 2019 is $2040.

Join us with Medicare compliance expert, Nancy Beckley, for a live webinar on December 11th to learn more about coming Medicare changes in 2019. Space is limited so register today.

On the Horizon

Special modifiers, together with a “special” fee schedule for PT and OT assistants of 85% of the fee schedule for PTs and OTs will be the law of the land. It is not in effect until 2020 though, obviously, this will have a profound effect on our professions.

Final Preparations

How can you help get prepared for 2019 based on the Final Rule?

  • If you are a Medicare Provider, and you have not already, familiarize yourself with MIPS. A helpful place to start is in our MIPS Resource Center, which includes recordings of prior webinars, infographics, blogs, and summary documents.
  • Profile your practice to see whether or not you will be required to participate.
  • Determine the best data submission method for your practice and leverage EMR, patient engagement and outcomes tools to simplify quality reporting.
  • Educate your entire staff of the other big changes in Functional Limitation Reporting and the Cap. As always, let us know if we can help clarify anything or assist in any way to prepare you for success in 2019.

For our part, we’re busy making sure that there are no surprises inserted into the final rule, adjusting to any surprises, summarizing the impactful rules for our clients, and double checking the systems and processes we have developed in anticipation of the Final Rule. Happy end of the year!


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